1 Jerry Flanagan (SBN 271272) 2 [email protected] Benjamin Powell (SBN 311624) 3 [email protected] CONSUMER WATCHDOG 4 6330 San Vicente Blvd., Suite 250 Los Angeles, CA 90048 5 Tel: (310) 392-0522 6 Fax: (310) 392-8874

7 Kelly Aviles (SBN 257168) [email protected] 8 LAW OFFICES OF KELLY AVILES 9 1502 Foothill Blvd., Suite 103-140 La Verne, CA 91750 10 Tel: (909) 991-7560 Fax: (909) 991-7594 11 Attorneys for Petitioner/Plaintiff 12 13

14

15 SUPERIOR COURT OF THE STATE OF CALIFORNIA 16 FOR THE COUNTY OF LOS ANGELES 17 18 CONSUMER WATCHDOG, a non-profit CASE NO. organization, 19 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR 20 Petitioner/Plaintiff, DECLARATORY RELIEF

21 v. (Code Civ. Proc. §§ 1060, 1085; Public Records 22 Act, Gov. Code § 6250 et seq.)

23 RICARDO LARA, in his official capacity as the Insurance Commissioner of the State of 24 California; CALIFORNIA DEPARTMENT OF 25 INSURANCE; and DOES 1–50,

26 Respondents/Defendants. 27 28

VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF

1 Petitioner/Plaintiff Consumer Watchdog alleges as follows: 2 INTRODUCTION 3 1. This Petition and Complaint challenges the validity of California Insurance Commissioner 4 Ricardo Lara, who is sued here in his official capacity, and the California Department of Insurance’s 5 refusal to provide certain records in response to two California Public Records Act requests (Government 6 Code section 6250 et seq. (“PRA”)) submitted by Consumer Watchdog. 7 2. The Department of Insurance is the nation’s largest state regulatory agency. It is 8 responsible for regulating the $310 billion insurance industry in California and keeping insurance 9 available and affordable. The Department of Insurance is subject to the PRA. 10 3. The PRA was enacted for the purpose of increasing freedom of information by giving the 11 public access to information in possession of public agencies. As the California Supreme Court has 12 opined, “[a]n informed and enlightened electorate is essential to a representative democracy.” (Times 13 Mirror Co. v. Superior Court (1991) 53 Cal.3d 1325, 1328.) This principle is now enshrined in the state 14 Constitution following the adoption of a voter-approved initiative in 2004: “The people have the right of 15 access to information concerning the conduct of the people’s business, and therefore, . . . the writings of 16 public officials and agencies shall be open to public scrutiny.” (Cal. Const., art. I, § 3, subd. (b)(1).) 17 4. The PRA requests at issue here focus on $54,300 in campaign contributions 18 Commissioner Lara received from individuals linked to two insurance companies, Applied Underwriters 19 (formerly a Berkshire-Hathaway Company) and Independence Holding Company (“IHC”), after 20 Commissioner Lara pledged not to take contributions from companies regulated by the Department of 21 Insurance. In some instances, Commissioner Lara received large contributions from the relatives of 22 insurance industry executives. The structuring of these contributions was apparently intended to conceal 23 their true origins. 24 5. Shortly after receiving the contributions, Defendant Lara intervened in four proceedings 25 involving one of the insurers, Applied Underwriters. Defendant Lara admitted publicly that he met with 26 27 28 1 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 the President of Applied Underwriters, Steven M. Menzies, prior to intervening in the proceedings, and 2 that Menzies requested he review the cases.1 3 6. In the four proceedings, Administrative Law Judges (“ALJs”) initially ordered Applied 4 Underwriters to refund excess payments made by employers that purchased Applied’s workers’ 5 compensation insurance policies. These workers’ compensation insurance plans had been deemed “bait 6 and switch” by Commissioner Lara’s predecessor, yet Commissioner Lara ordered the ALJs to reverse 7 course by requiring employers to pay whatever Applied claims was owed. At stake are potentially 8 hundreds of millions of dollars that Applied wants to collect from policy purchasers. 9 7. Menzies also stands to gain if Commissioner Lara ultimately approves his purchase of 10 Applied Underwriters, which requires Commissioner Lara to agree to the sale of Applied’s California 11 affiliate, California Insurance Company. The Department of Insurance has recently entered into 12 conservatorship of California Insurance Company “with the goal of obtaining [purchase] approval and 13 settlement of disputes with [the Department of Insurance].” (A true and correct copy of the order 14 appointing the Department of Insurance as conservator is attached as Exhibit 1 and incorporated by this 15 reference.)2 16 8. Commissioner Lara also received contributions from an individual associated with IHC. 17 On information and belief, IHC is one of the largest sellers in the United States of short-term “junk” 18 health insurance policies, which have been banned in California. 19 9. As discussed more fully below, Respondents/Defendants initially refused to provide 20 Insurance Commissioner Ricardo Lara’s schedule of meetings and communications with insurance 21 industry representatives and related documents in response to Consumer Watchdog’s PRA requests. 22 Following the Department of Insurance’s initial refusal to provide the records, Consumer Watchdog 23 significantly narrowed the PRA requests to focus on the specific individuals and companies associated 24 with the campaign contributions. While the Department of Insurance eventually agreed to produce some

25 1 Lily Jamali, State Insurance Commissioner Defends Intervening in Cases Involving His Donors, 26 KQED (July 25, 2019), https://www.kqed.org/news/11763205/state-insurance-commissioner-defends- intervening-in-cases-involving-his-donors. 27 2 All of the exhibits referenced herein are true and correct copies of the documents they purport to be and are incorporated herein by reference as though they were set forth in full. 28 2 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 responsive records, the production was grossly inadequate and failed to uphold Commissioner Lara and 2 the Department of Insurance’s duties under the PRA. For example, instead of turning over copies of the 3 original records, the Department of Insurance appears to have created a summary of Lara’s meetings, 4 raising significant questions about what it is withholding. Additionally, the Department of Insurance 5 claims it is withholding other records under various claims of exemption but refuses to provide any 6 additional information about what types or how many records it is withholding or the factual basis for its 7 claims of exemption. 8 10. Based on the records that were turned over by the Department of Insurance, it appears that 9 many additional communications between Commissioner Lara and insurance company representatives 10 have been withheld, which raises more questions about whether Applied Underwriters and IHC were 11 attempting to use campaign contributions to influence Commissioner Lara’s decision-making process on 12 policy matters affecting the two companies. Disclosing the remaining records is essential to restore the 13 public trust in the Office of the Insurance Commissioner in the wake of widespread reports of influence 14 peddling involving Commissioner Lara and insurance companies regulated by the Department of 15 Insurance.3 16

17 3 See, e.g., Jeff McDonald, State’s Top Insurance Regulator Accepted Tens Of Thousands Of Dollars From Industry Executives, Records Show, San Diego Union Tribune (July 7, 2019), 18 https://www.sandiegouniontribune.com/news/watchdog/story/2019-07-05/states-top-insurance- 19 regulator-accepted-tens-of-thousands-of-dollars-from-industry-executives-records-show; Jeff McDonald, Insurance Commissioner Will Return Funds From Companies With Ties To Industry He 20 Regulates, San Diego Union Tribune (July 8, 2019), https://www.sandiegouniontribune.com/news/watchdog/story/2019-07-08/insurance-commissioner-will- 21 unhand-funds-from-companies-with-ties-to-industry-he-regulates; Editorial: Insurance Commissioner 22 Lara Never Should Have Accepted Donations From Those He Regulates, San Diego Union Tribune (July 8, 2019), https://www.sandiegouniontribune.com/opinion/editorials/story/2019-07-08/insurance- 23 commissioner-lara-donations-insurance-companies; Hannah Wiley, California’s Sustainable Development + Lara’s Campaign Contribution + Earthquake State of Emergency, Sacramento Bee 24 (July 10, 2019), https://www.sacbee.com/site-services/newsletters/capitol- morning/article232453557.html; Editorial: Insurance Commissioner’s Campaign Cash Scandal Raises 25 Troubling Questions, Sacramento Bee (July 10, 2019), 26 https://www.sacbee.com/opinion/editorials/article232509952.html; Editorial: Troubling Behavior From California’s Insurance Commissioner Ricardo Lara, Los Angeles Times (June 11, 2019), 27 https://www.latimes.com/opinion/editorials/la-ed-ricardo-lara-insurance-donations-20190711- story.html; Editorial: Thumbs Down: Ricardo Lara’s Broken Promise, Santa Rosa Press-Democrat (July 28 12, 2019), https://www.pressdemocrat.com/opinion/9790544-181/thumbs-down-ricardo-laras-broken. 3 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 11. The public interest at stake is significant. “Openness in government is essential to the 2 functioning of a democracy.” (International Federation of Professional & Technical Engineers, Local 3 21, AFL-CIO v. Superior Court (2007) 42 Cal.4th 319, 329.) “Implicit in the democratic process is the 4 notion that government should be accountable for its actions; in order to verify accountability, individuals 5 must have access to government files to permit checks against the arbitrary exercise of official power 6 and secrecy in the political process.” (C.B.S., Inc. v. Block (1986) 42 Cal.3d 646, 651; International 7 Federation of Professional & Technical Engineers, supra, 42 Cal.4th at 329 [same]; Marken v. Santa 8 Monica-Malibu Unified School Dist. (2012) Cal.App.4th 1250, 1261 [same]; Sonoma County 9 Employees’ Retirement Association v. Superior Court (2011) 198 Cal.App.4th 986, 991 [same]; San 10 Diego County Employees Retirement Association v. Superior Court of San Diego County (2011) 196 11 Cal.App.4th 1228, 1235 [same]; Los Angeles Unified School Dist. v. Superior Court (2007) 151 12 Cal.App.4th 759, 764 [same].) 13 12. “Public disclosure is a critical weapon in the fight against government corruption. 14 Whether there is a real impropriety or merely the appearance of an impropriety, the public has a right to 15 know the particulars.” (Kunec v. Brea Redevelopment Agency (1997) 55 Cal.App.4th 511, 515.) The 16 people of California deserve transparency and certainty as to whether our elected leaders are living up to 17 the trust the voting public has invested in them. Commissioner Lara deserves to have his name cleared if 18 he is innocent of any wrongdoing. Full disclosure of records reflecting Commissioner Lara’s schedule of 19 meetings and communications with political donors is essential to answer these questions. 20 PARTIES 21 13. Petitioner/Plaintiff Consumer Watchdog is a nationally recognized, California-based non- 22 profit group organized to provide an effective voice for American consumers in an era when special 23 interests dominate public discourse, government, and politics. One of Consumer Watchdog’s chief 24 missions is to follow the money trail from special interests to policymakers and trace public policy 25 decisions back from politicians to their donors. Consumer Watchdog does so by researching the public 26 policy impact of political contributions to elected officials and educating the public through investigative 27 reports, blogs, news releases, online videos, contributing to news stories published in the state’s largest 28 newspapers, and participating in television news reports and radio news broadcasts. Consumer 4 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 Watchdog’s website, ConsumerWatchdog.org, has had more than 67,000 visitors in a single month. 2 Consumer Watchdog has 82,000 Facebook fans and over 6,800 Twitter followers. Consumer Watchdog 3 has conducted public education and advocacy to increase public accountability of state and local 4 officeholders including by: 5 a. Launching CapitolWatchdog.org, a website pulling back the curtain on elected 6 officials and regulators in Sacramento and the special interests that seek to influence them. 7 b. Publishing investigative reports such as the “California Betrayed” series that 8 highlight key areas in which the interests of regular Californians are subsumed to corporate 9 interests. For example, Consumer Watchdog’s report Betting Against The House: How 10 California’s Leaders Could Gamble Away Our Energy Future On A Western Power Trading 11 Casino exposed a plan by former Enron allies and the designers of California’s failed electricity 12 deregulation laws to bring back a deregulation-era policy to commoditize electricity that would 13 leave ratepayers subject to speculators’ whims. 14 c. Chronicling how the devastating wildfires in the state became another area in 15 which consumers had a lot to lose to industry lobbying in the Legislature, such as PG&E- 16 sponsored legislation aimed at forcing ratepayers to pay the costs of any wildfire damage, even 17 when the utility’s own negligence was the direct cause of the fire. 18 d. Exposing the hidden hand of the utility, oil, and gas industries over state 19 policymaking at the Public Utilities Commission (“PUC”) and in the state Capitol through 20 investigative reports and creation of a website, PUCPapers.org. The website published thousands 21 of primary source documents and emails exchanged between PG&E and other utility executives 22 and government officials that were unearthed in a corruption scandal that led to the criminal 23 investigation of PUC president Michael Peevey and scrutiny of other PUC Commissioners. 24 e. Authoring investigative reports such as Power Play, chronicling how Sempra 25 shareholders profited wildly from the favorable decisions taken by Governor Brown’s appointees. 26 Governor Brown’s sister Kathleen Brown, a Sempra board member, made more than $1 million 27 in cash and stock after joining the board. 28 5 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 f. Educating policymakers and the public about the influence of the powerful tech 2 lobby that had historically blocked meaningful online privacy reform in Sacramento. Consumer 3 Watchdog shined a spotlight on the anti-privacy positions of the giant tech companies who put 4 up money to oppose a landmark online privacy ballot measure, including Google, Facebook, 5 Verizon, and AT&T. These efforts resulted in legislation—AB 375 (Chau)—signed by then- 6 Governor Jerry Brown, creating the nation’s strongest privacy protections. 7 g. Launching LA Watchdog to uncover the public impact of political influence at the 8 Los Angeles Department of Water and Power and City Hall. 9 h. Pioneering ArnoldWatch.org, a website exposing special interests’ influence on 10 then-Governor Arnold Schwarzenegger. 11 i. Uncovering influence peddling of former California Insurance Commissioner 12 Chuck Quackenbush, which ultimately resulted in his resignation from office. 13 j. Policing the insurance industry’s attempts to inappropriately influence state 14 officials and public decisions by publishing information about insurance industry financial 15 contributions to elected officials and ballot campaigns, and exposing insurance industry lobbying 16 to undermine landmark state insurance regulation enacted by voters in 1988, insurance reform 17 Proposition 103. The ballot reform, authored by Consumer Watchdog’s founder, Harvey 18 Rosenfield, has saved drivers over $150 billion on their auto insurance bills, according to a 2018 19 Consumer Federation of America report. 20 k. Filing complaints with the state ethics watchdog, the Fair Political Practices 21 Commission (FPPC), resulting in fines for financial conflicts of interest and reporting violations 22 by numerous public officials and entities, including, for example: former Governor Jerry Brown’s 23 chief of staff, Nancy McFadden, for failing to disclose significant financial holdings in her 24 previous employer, PG&E, and the state Democratic Party, for failing to properly account for 25 campaign contributions from the oil industry. Most recently the FPPC is currently investigating 26 two state oil regulators for holding stock in the oil companies they regulate, based on complaints 27 filed by Consumer Watchdog last summer. The Governor removed the deputy director of the 28 Department of Conservation and the head of the Division of Oil, Gas, and Geothermal Resources 6 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 (formerly DOGGR, now CalGEM) following complaints and disclosures by Consumer Watchdog 2 about rampant conflicts-of-interest at DOGGR. 3 14. Respondent and Defendant Ricardo Lara is Commissioner of the Department of Insurance 4 and is sued herein in his official capacity. Commissioner Lara was sworn into office on January 7, 2019. 5 Pursuant to Insurance Code section 12906, the Department of Insurance is “under control of the Insurance 6 Commissioner.” As required by statute, and at all times relevant herein, Commissioner Lara “shall 7 perform all duties imposed upon him or her by the provisions of this code and other laws regulating the 8 business of insurance in this state, and shall enforce the execution of those provisions and laws.” (Ins. 9 Code § 12921(a).) 10 15. Respondent and Defendant the California Department of Insurance is the nation’s largest 11 consumer protection agency. With annual direct premiums of $310 billion, California is the largest 12 insurance market in the United States and the fourth largest insurance market in the world. The 13 Department of Insurance enforces the insurance laws of California and has authority over how insurers 14 and licensees conduct business in California. In 1988, California voters passed Proposition 103, a citizen- 15 led initiative that expanded the Department of Insurance’s authority as well as changed the Insurance 16 Commissioner from an appointee of the Governor to an independent statewide officer elected by popular 17 vote in order to increase public accountability. 18 16. Consumer Watchdog is unaware of the true names and capacities of 19 Respondents/Defendants DOES 1 through 50, inclusive, and they are therefore sued by such fictitious 20 names pursuant to Code of Civil Procedure section 474. Consumer Watchdog alleges on information and 21 belief that each such fictitiously named Respondent and Defendant is responsible or liable in some 22 manner for the events and happenings referred to herein, and Consumer Watchdog will seek leave to 23 amend this Petition and Complaint to allege their true names and capacities after the same have been 24 ascertained. 25 STANDING 26 17. Government Code section 6258, subdivision (a) provides that “[a]ny person may institute 27 proceedings for injunctive or declarative relief or writ of mandate in any court of competent jurisdiction 28 7 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 to enforce his or her right to inspect or to receive a copy of any public record or class of public records 2 under this chapter.” 3 18. “Person” is defined in Government Code section 6252, subdivision (c) to include “any 4 natural person, corporation, partnership, limited liability company, firm, or association . . . .” The term 5 “person” as used in the PRA has been interpreted broadly. (Los Angeles Unified School Dist., supra, 151 6 Cal.App.4th at 771; see also Connell v. Superior Court (1987) 56 Cal.App.4th 601, 611 [holding under 7 the PRA that “person” includes “any corporation”] [internal citations omitted]; North County Parents 8 Organization for Children with Special Needs v. Department of Education (1994) 23 Cal.App.4th 144, 9 148, reh’g denied (March 31, 1994), review denied (May 19, 1994) [Pursuant to the PRA, a “person” 10 includes a non-profit, tax-exempt organization]; see also Sierra Club v. Superior Court (2013) 57 Cal.4th 11 157, 163 [a non-profit environmental group may sue to obtain government records].) 12 19. Consumer Watchdog, a non-profit, charitable organization, is a “person” entitled to 13 institute proceedings for injunctive or declarative relief or writ of mandate to compel the Department of 14 Insurance to disclose public records pursuant to the PRA. 15 JURISDICTION AND VENUE 16 20. This Court has jurisdiction to issue writs of mandate pursuant to Code of Civil Procedure 17 section 1085, subdivision (a), and in the case of the PRA, pursuant to Government Code section 6259, 18 subdivision (a), as the requested records are situated in and accessible electronically from the Department 19 of Insurance’s computer-based file systems in Los Angeles County. Specifically, Commissioner Lara 20 maintains the records at the Department of Insurance’s Los Angeles office located at 300 South Spring 21 Street, South Tower in Los Angeles, California. Commissioner Lara’s primary residence is in Los 22 Angeles and Commissioner Lara primarily works out of the Department of Insurance’s Los Angeles 23 office. The Court has jurisdiction to grant injunctive and declaratory relief pursuant to Code of Civil 24 Procedure sections 525, 526, and 1060. 25 21. Venue is proper in the County of Los Angeles pursuant to Code of Civil Procedure section 26 393, subdivision (b). 27 28 8 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 PRA REQUESTS AND MEET AND CONFER EFFORTS 2 22. On June 4, 2019, Consumer Watchdog submitted a PRA request that, in part, sought the 3 following records (“Request 1”):4

4 All appointment schedules, calendars, meeting logs, phone call logs, mobile phone records, and any other records relating to any meetings or phone calls (“Conferences”) between 5 Insurance Commissioner Lara and any individuals who are employed by or represent the 6 interests of one or more insurance companies or the insurance industry. This request includes but is not limited to records providing the identities of the individuals participating 7 in the Conferences as well as records reflecting when and where the Conferences occurred. 8 (A true and correct copy of Consumer Watchdog’s initial June 4, 2019 PRA request is attached as Exhibit 9 2 and incorporated by this reference.) 10 23. On June 7, 2019, a representative of the Department of Insurance sent an email 11 acknowledging receipt of the PRA request, stating that the PRA request “as currently written, is 12 overbroad and will be unduly burdensome on staff to search for responsive records.” (A true and correct 13 copy of Department of Insurance’s June 7, 2019 email is attached as Exhibit 3 and incorporated by this 14 reference.) 15 24. On June 11, 2019, attorneys for Consumer Watchdog participated in a telephonic 16 conference with counsel for the Department of Insurance. During that conference, counsel for the 17 Department of Insurance requested that attorneys for Consumer Watchdog narrow Request 1: (1) to 18 define the time period during which records were sought, and (2) specify the individuals and/or 19 companies that Consumer Watchdog believed participated in Conferences with Commissioner Lara for 20 which records were sought. Attorneys for Consumer Watchdog explained that Consumer Watchdog was 21 broadly investigating the potential influence of the insurance industry over the Department of Insurance 22 and could not narrow the list of insurance company representatives to specified individuals as requested. 23 However, attorneys for Consumer Watchdog agreed to define the time period for which records were 24 sought, as reflected in a June 11, 2019 letter to the Department of Insurance. (A true and correct copy of 25 Consumer Watchdog’s June 11, 2019 letter is attached as Exhibit 4 and incorporated by this reference.) 26 27 4 Though the June 4, 2019 PRA request sought other records, this action relates solely to Request 1 of 28 the June 4, 2019 PRA, as subsequently modified, and the additional PRA request sent July 19, 2019. 9 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 25. In an email dated July 5, 2019, a representative for the Department of Insurance 2 summarily concluded regarding Request 1:

3 There are responsive records to this request which are not being produced. These records are privileged or confidential and exempt from disclosure under Insurance Code section 4 12919, Government Code section 6254, subdivisions (d), (f), and (k), Evidence Code 5 sections 1040 and 1041, and the deliberative process privilege. (See Gov. Code § 6255; see also Times Mirror Co. v. Superior Court (1991) 53 Cal.3d 1325.). To the extent there 6 are attorney-client communications or attorney work product, these records are confidential and exempt from disclosure under the attorney-client privilege and the attorney work 7 product doctrine. 8 26. On July 11, 2019, counsel for Consumer Watchdog sent a letter to the Department of 9 Insurance explaining why Respondents/Defendants’ refusal to comply with Request 1 had no basis in 10 law. (A true and correct copy of Consumer Watchdog’s July 11, 2019 letter is attached as Exhibit 5 and 11 incorporated by this reference. A true and correct copy of the Department Insurance’s July 5, 2019 email 12 is attached as exhibit A to the July 11, 2019 letter.) 13 27. Though Consumer Watchdog disagreed with the basis of the Department of Insurance’s 14 refusal to provide public records in response to Request 1, Consumer Watchdog narrowed the PRA 15 request once more in order to facilitate a prompt disclosure of records. As specified in the July 11, 2019 16 letter, Request 1 was narrowed to reflect “records pertaining to the individuals and companies” associated 17 with specific financial contributions to Commissioner Lara. Counsel for Consumer Watchdog wrote “by 18 this letter Request 1 is amended as follows”: 19 All appointment schedules, calendars, meeting logs, phone call logs, mobile phone records, 20 and any other records relating to any meetings or phone calls (“Conferences”) between Insurance Commissioner Lara or his representatives, including staff of the Department, and 21 the following individuals: Steven M. Menzies, Jeffrey A. Silver, Stephen Acunto, Carole Acunto, Carl DeBarbrie, Theresa DeBarbrie, Sidney R. Ferenc, Jon M. McCright, Marc M. 22 Tract, Robert L. Stafford, Justin N. Smith, Darlene Graber, and Larry R. Graber. This 23 request also includes records of Conferences between Insurance Commissioner Lara and any individuals employed by or representing Applied Underwriters, California Insurance 24 Company (“CIC”), Constitution Insurance Company, or Independence Holding Company (“IHC”). This request includes, but is not limited to, records providing the identities of the 25 individuals participating in the Conferences as well as records reflecting when and where the Conferences occurred and the topics of those Conferences. This request seeks records 26 from January 7, 2019 to the present. 27 28 10 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 The letter established a July 31, 2019 deadline for Respondents/Defendants to comply with the request 2 before Consumer Watchdog would commence the instant litigation. 3 28. On July 22, 2019, Respondents/Defendants requested via email that Consumer Watchdog 4 further narrow the Request 1 by providing the names of specific Department of Insurance employees for 5 whom responsive records were being sought. (A true and correct copy of the email exchange is attached 6 as Exhibit 6 and incorporated by this reference.) 7 29. On July 23, 2019, counsel for Consumer Watchdog narrowed Request 1 yet again by 8 providing the requested list of Department of Insurance employees (“July 23, 2019 Revised Request”). 9 (A true and correct copy of the July 23, 2019 letter is attached as Exhibit 7 and incorporated by 10 reference.) The July 23, 2019 Revised Request is the final version of the PRA request that is subject to 11 this action. 12 30. On September 4, 2019, the Department of Insurance provided a number of responsive 13 records, primarily consisting of email correspondence among various Department of Insurance 14 employees and Commissioner Lara’s campaign staff. Counsel for Consumer Watchdog sent an email to 15 Respondents/Defendants on September 5, 2019 reiterating that as per the July 23, 2019 Revised Request, 16 the Department of Insurance was required to produce the meeting calendar for Commissioner Lara from 17 January 7, 2019 through August 31, 2019. 18 31. On September 13, 2019, Defendants finally produced what they claimed to be 19 Commissioner Lara’s calendar for the above date range. However, it was obvious from the face of the 20 production that it was grossly deficient for a number of reasons. Rather than producing Commissioner 21 Lara’s actual calendar, the Department of Insurance appears to have created a new record claiming to be 22 the calendar. Consumer Watchdog is informed and believes and, on that basis, alleges that the 23 Department of Insurance created the new records to avoid redacting the original records to avoid scrutiny 24 of the entries that were withheld from public disclosure. The summary created by the Department of 25 Insurance contains no redactions, and instead contains calendar entries consisting of unnatural phrases 26 including “No responsive calendar entries,” and language in daily calendar entries indicating that the 27 records were sanitized before being produced (e.g., “Lunch w/ only Steve Menzies & Jamie Sahara”) 28 11 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 (emphasis added). (A true and correct copy of the Department of Insurance’s summary of Commissioner 2 Lara’s calendar is attached hereto as Exhibit 8 and incorporated by this reference.) 3 32. Consumer Watchdog is informed and believes, and on that basis, alleges that 4 Commissioner Lara’s official calendar entries are often accompanied by “notes” containing details of the 5 Commissioner’s planned events, meetings, and appointments. None of the calendar entries provided by 6 the Department of Insurance contain any such notes, nor were any meeting agenda records, meeting 7 notes, internal memos, internal communications regarding the meetings, or phone call logs provided in 8 the production. 9 Parallel PRA Request for Commissioner Lara’s Communications 10 33. On July 19, 2019, counsel for Consumer Watchdog sent a letter to the Department of 11 Insurance detailing a second parallel PRA request, requesting email or any other communications 12 between Commissioner Lara and the same individuals listed in the July 23, 2019 Revised Request. 13 Specifically, the request sought:

14 All e-mail or any other communications (“Communications”) between Insurance Commissioner Lara or his representatives, including staff of the Department, and the 15 following individuals: Steven M. Menzies, Jeffrey A. Silver, Stephen Acunto, Carole 16 Acunto, Carl DeBarbrie, Theresa DeBarbrie, Sidney R. Ferenc, Jon M. McCright, Marc M. Tract, Robert L. Stafford, Justin N. Smith, Darlene Graber, or Larry R. Graber. This 17 request also includes Communications between Insurance Commissioner Lara or his representatives, including staff of the Department, any individuals employed by or 18 representing Applied Underwriters, California Insurance Company, Constitution Insurance 19 Company, or Independence Holding Company. This request includes, but is not limited to, records providing the identities of the individuals participating in the Communications, the 20 topics of those Communications, and the contents of those Communications. This request includes, but is not limited to, any Communications regarding matters pending before the 21 Department, including before the Administrative Hearing Bureau. This request seeks records from January 7, 2019 to the present. 22 (“July 19, 2019 Request.”) (A true and correct copy of the July 19, 2019 Request is attached as 23 Exhibit 9 and incorporated by this reference.) 24 34. On September 16, 2019, the Department of Insurance produced some records in response 25 to the July 19, 2019 Request, indicating that it had withheld numerous other records pursuant to various 26 claims of privilege and/or exceptions to the PRA, but did not provide any information about what types 27 or how many records it withheld, nor did it provide the factual basis for its claims of exemption. Only a 28 12 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 single email from and a single text message to Commissioner Lara were produced. (A true and correct 2 copy of the Department of Insurance’s September 16, 2019 correspondence and production is attached 3 as Exhibit 10 and incorporated by this reference.) 4 35. On September 17, 2019, Counsel for Consumer Watchdog sent a letter to the Department 5 of Insurance, requesting that the Department of Insurance provide a “privilege log” for both PRA requests 6 containing a summary description of the subject matter of each withheld record and the basis for the 7 claimed privilege or exemption, so that Counsel for Consumer Watchdog would be able to test the 8 claimed privileges and exemptions. (A true and correct copy of the September 17, 2019 correspondence 9 is attached as Exhibit 11 and incorporated by this reference.) 10 36. In response, on September 27, 2019, the Department of Insurance sent a letter indicating 11 it would not provide the requested privilege log. (A true and correct copy of this response is attached as 12 Exhibit 12 and incorporated by this reference.) 13 37. On October 22, 2019, counsel for Consumer Watchdog sent a letter to the Department of 14 Insurance, again outlining the deficiencies of the Department of Insurance’s responses to the two PRA 15 requests. The letter requested that the Department of Insurance provide additional information that would 16 allow counsel for Consumer Watchdog to determine whether the claimed exemptions and privileges were 17 justified and demanded the Department of Insurance produce actual copies of Commissioner Lara’s 18 calendar records in their native format. (A true and correct copy of this request is attached as Exhibit 13 19 and incorporated by this reference.) 20 38. In a letter dated October 31, 2019, the Department of Insurance refused to provide 21 Commissioner Lara’s calendars in their native format, apparently conceding that it had not produced the 22 actual public records and had instead created a new, scrubbed summary of the responsive records. The 23 Department of Insurance also refused to provide any supplemental information that would allow counsel 24 for Consumer Watchdog to determine whether the claimed exemptions and privileges were justified. (A 25 true and correct copy of this response is attached as Exhibit 14 and incorporated by this reference.) 26 27 28 13 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 PUBLIC INTEREST ISSUES AT STAKE5 2 39. As explained in the July 11, 2019 letter attached as Exhibit 5, each of the individuals and 3 companies identified in the July 23, 2019 Revised Request and July 19, 2019 Request raise significant 4 public interest issues, as it appears these individuals and companies were attempting to inappropriately 5 use campaign contributions to influence Commissioner Lara’s decision-making on important public 6 matters in violation of state and federal law. 7 40. Steven M. Menzies is identified as the individual acquiring California Insurance Company 8 in a document filed with the Department of Insurance. (A true and correct copy of that document is 9 attached as Exhibit 15 and incorporated by this reference.) Mr. Menzies is also President of Constitution 10 Insurance Company, whose directorate interlocks with Applied Underwriters and California Insurance 11 Company, several members of which have made financial contributions to Commissioner Lara’s 2022 12 re-election campaign. Jeffrey A. Silver is identified in Exhibit 15 as an attorney representing Mr. Menzies 13 in the California Insurance Company transaction and is Treasurer of Constitution Insurance Company. 14 Sidney R. Ferenc, Jon M. McCright, Marc M. Tract, Robert L. Stafford, and Justin N. Smith are all listed 15 as Directors or Officers of California Insurance Company in Exhibit 15. 16 41. Three of the individuals listed in the two PRA requests who have made financial 17 contributions to Commissioner Lara’s 2022 re-election campaign—Stephen and Carole Acunto and 18 Theresa DeBarbrie—are connected to Applied Underwriters and its subsidiary California Insurance 19 Company (“CIC”). In official reports filed with the Secretary of State, Commissioner Lara or his 20 representatives identified Ms. DeBarbrie, who contributed $15,500, as an “Administrative Coordinator” 21 for a nursery school in New Jersey. Theresa DeBarbrie’s husband is apparently Carl DeBarbrie, an 22 insurance broker for Applied Underwriters and former executive with Constitution Insurance Company 23 and CIC. Mr. DeBarbrie did not make a financial contribution directly to Commissioner Lara. The 24 contribution was apparently made in Ms. DeBarbrie’s name to conceal its true origin. 25 26

27 5 Certain allegations set forth in this section are made on information and belief and included to provide context and background regarding the PRA violations at issue. 28 14 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 42. Ms. Acunto, who also contributed $15,500, was identified as president of a media 2 company in Connecticut. Her husband Stephen Acunto is Managing Director of the Constitution Group, 3 which wholly owns Constitution Insurance Company. Mr. Acunto is also a spokesperson for Applied 4 Underwriters. (A true and correct copy of the contributions report filed with the California Secretary of 5 State on behalf of Ricardo Lara’s 2022 re-election campaign is attached as Exhibit 16 and incorporated 6 by this reference.) 7 43. A fourth donor to Commissioner Lara, Darlene Graber, is apparently the wife of Larry R. 8 Graber, who is Senior Vice President and Director of IHC. IHC is one of the largest sellers of short-term 9 “junk” health insurance in the United States.6 California banned short-term insurance in 2018.7 Ms. 10 Graber, who contributed $7,800 to Commissioner Lara’s 2022 re-election fund, is identified as a 11 “homemaker” in the reports filed with the Secretary of State. Mr. Graber did not make a financial 12 contribution directly to Commissioner Lara. The contribution was apparently made in Ms. Graber’s name 13 to conceal its true origin. 14 44. The public has an interest in knowing whether Commissioner Lara or his representatives 15 met with and/or communicated with these individuals, as the campaign contributions appear to have been 16 intended to inappropriately influence Commissioner Lara’s decisions regarding the administrative law 17 cases before the Department of Insurance and the sale of California Insurance Company. In the case of 18 IHC, the purpose of the political contributions may have been to encourage support for IHC’s efforts to 19 re-enter the California market. 20 45. The people of California deserve transparency and certainty as to whether our elected 21 leaders are living up to the trust the voting public has invested in them. The pay-to-play scandal has led 22 policymakers, editorial board editors, other thought leaders, and the public to question whether 23 Commissioner Lara has broken the law and whether he will be able to finish his term as Insurance 24

25 6 26 Robert Pear, Trump’s Short-Term Health Insurance Policies Quickly Run Into Headwinds, N.Y. Times (Aug. 6, 2018), https://www.nytimes.com/2018/08/06/us/politics/trump-short-term-health-plans.html. 27 7 Catherine Ho, Defying Trump, California Legislature Bans Short-Term Health Insurance, S.F. Chronicle (Aug. 20, 2018), https://www.sfchronicle.com/business/article/Defying-Trump-California- 28 legislature-bans-13169686.php. 15 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 Commissioner. Department of Insurance staff report dismal morale that has taxed the ability of the state’s 2 largest administrative agency to effectively oversee California’s $310 billion insurance industry.

3 RECORDS PRODUCED BY THE DEPARTMENT OF INSURANCE DEMONSTRATE 8 4 PUBLIC INTEREST IN FULL DISCLOSURE 46. The records the Department of Insurance has produced, when viewed in conjunction with 5 other publicly available information, give rise to a number of concerning issues that bolster Consumer 6 Watchdog’s assertions that the withheld documents and records are of significant public interest. For 7 example, emails and calendar entries produced by the Department of Insurance demonstrate that 8 Commissioner Lara, his political fundraiser Dan Weitzman, Department of Insurance staff, and principals 9 of Applied Underwriters simultaneously discussed political fundraising and policy matters pending 10 before the Department of Insurance. (A summary of the records is attached as Exhibit 17 and 11 incorporated by this reference.) 12 47. Documents provided by the Department of Insurance show that former New 13 Mexico Superintendent of Insurance Eric Serna, who resigned in disgrace in the wake of a pay-to-play 14 fundraising scandal, was involved in Commissioner Lara’s review of the sale of California Insurance 15 Company to Steve Menzies. Photographs uncovered by Consumer Watchdog demonstrated that Serna 16 and Commissioner Lara were together in late February 2019 in Santa Fe. Records produced by the 17 Department of Insurance show that one day after Commissioner Lara’s return from Santa Fe on March 1, 18 2019, Commissioner Lara’s fundraiser Dan Weitzman, Commissioner Lara, and his Department of 19 Insurance staff exchanged emails discussing meetings with the Menzies team about both fundraising and 20 California Insurance Company’s change of ownership. 21 48. On March 12, 2019, Commissioner Lara attended a fundraising meeting, described as a 22 “Relationship Building Lunch with Eric Serna & Berkshire Hathaway” “to benefit Ricardo Lara for 23 Insurance Commissioner 2022” at Camden, Spit & Larder in Sacramento. Attendees at that meeting 24 included: Commissioner Lara; Steve Menzies, CEO of Applied Underwriters; Jeff Silver, Applied 25 Underwriters counsel; Jamie Sahara, Chairman of Cayman Islands–based United Insurance Company, 26 27 8 Certain allegations set forth in this section are made on information and belief and included to provide 28 context and background regarding the PRA violations at issue. 16 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 who was also apparently involved in the Applied/California Insurance Company sale; Camille Alcala, 2 California Democratic Party Deputy Director of Finance; Dan Weitzman; and Eric Serna. (A copy of the 3 meeting agenda (see Bates 000030) is included in Exhibit 18, which is a true and correct copy of the 4 communications produced by the Department of Insurance in response to the July 23, 2019 Revised 5 Request, and is incorporated by this reference.) 6 49. On the same day, March 12, 2019, a follow-up internal Department of Insurance email 7 thread describes “the highlights of what was discussed” in a meeting with staff members and is heavily 8 redacted. On the same day, Jeff Silver, lawyer for the Berkshire-Hathaway subsidiaries including 9 Applied Underwriters, sent a follow-up email to Department of Insurance employees, saying, “thank you 10 for taking the time to visit with Eric, Steve Menzies and me concerning the soon to be filed Form A for 11 California Insurance Company. We look forward to working with you and your staff to meet the 12 September 30, 2019 deadline.” (Form A is the paperwork attached as Exhibit 15 seeking Commissioner 13 Lara’s approval of the acquisition of Applied Underwriters by Menzies.) 14 50. The fact that Dan Weitzman, Commissioner Lara’s political fundraiser, was involved in 15 multiple meetings regarding official Department of Insurance business is another troubling issue, as it 16 suggests that official Department of Insurance policy decisions were being discussed simultaneously with 17 fundraising and that one was being leveraged for the other. 18 51. As mentioned above, the Department of Insurance produced only one email from 19 Commissioner Lara—to the President of Consumer Watchdog—and only a single text message from 20 Commissioner Lara was produced, in which Lara approved a key meeting with principals of Applied 21 Underwriters. 22 52. Senator Lena Gonzalez’s name surfaces in the April 24, 2019 text message to 23 Commissioner Lara from a Department of Insurance employee’s phone, seeking to schedule a lunch in 24 May with “Lena Gonzales and Steve Menzies.” Commissioner Lara replied, “OK.” Individuals linked to 25 Applied Underwriters contributed $25,000 to Senator Lena Gonzalez, Commissioner Lara’s hand-picked 26 replacement for his California State Senate seat. Senator Gonzalez later paid an almost identical sum to 27 Dan Weitzman, Lara’s political consultant—creating the appearance that the campaign contributions to 28 17 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 Senator Gonzalez were funneled to Commissioner Lara’s fundraiser. (A true and correct copy of the text 2 message is attached as part of Exhibit 18 (Bates 000038.) 3 53. Additionally, in the below email from a conversation thread between Jamie Sahara, David 4 Green—Special Assistant at the Department of Insurance—and Dan Weitzman, Sahara discusses lunch 5 (presumably the same lunch discussed in the text messages described in paragraph 52) between 6 Weitzman, Gonzalez, Menzies, Sahara, and Lara:

7 We would like to schedule two meetings with the Commissioner:

8 1. Formal policy discussion with the Commissioner to discuss the California Insurance 9 Company.

10 2. Political meeting with the Commissioner, Lena Gonzalez, and Dan Weitzman[.] 11 (A true and correct copy of the email thread is attached as part of Exhibit 18 (Bates 000050-51) and 12 incorporated by this reference.) 13 54. While the above email suggests two meetings, only one appears to have been scheduled, 14 combining fundraising and policymaking into a single meeting. Records produced by the Department of 15 Insurance reflect a lunch meeting on May 6, 2019, from 12:00 – 2:00 pm at The NoMad Restaurant in 16 Los Angeles, with Commissioner Lara, Steve Menzies, and Jamie Sahara. (See Ex. 8.) 17 FIRST CAUSE OF ACTION

18 (Violation of the California Public Records Act, Gov. Code § 6250 et seq. 19 by Consumer Watchdog against all Respondents and Defendants)

20 (Writ of Mandate, Code Civ. Proc., § 1085; Gov. Code, §§ 6250 et seq.) 21 55. Consumer Watchdog re-alleges and incorporates by reference the allegations set forth in 22 paragraphs 1 through 54 above. 23 56. In enacting the PRA, the Legislature recognized that “access to information concerning 24 the conduct of the people’s business is a fundamental and necessary right of every person in this state.” 25 (Gov. Code, § 6250.) 26 57. The Legislature also recognized, through the passage of the PRA, that it is essential that 27 the requested public records be provided in a timely fashion by mandating that they be provided 28 “promptly” (id. at § 6253, subd. (b)), and by specifically requiring that the “times for responsive 18 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 pleadings and for hearings” in PRA cases be set “with the object of securing a decision as to these matters 2 at the earliest possible time” (id. at § 6258). 3 58. As the California Supreme Court has opined:

4 Unless one of the exceptions stated in the Act applies, the public is entitled to access to “any writing containing information relating to the conduct of the public’s business 5 prepared, owned, used, or retained by any state or local agency. . . . The records therefore 6 must be disclosed unless one of the statutory exceptions applies. The party seeking to withhold public records bears the burden of demonstrating that an exception applies. 7 (International Federation of Professional & Technical Engineers, Local 21, AFL-CIO, supra, 42 Cal.4th 8 at 329 [internal citations omitted].) 9 59. The Department of Insurance violated the PRA by refusing to produce to Consumer 10 Watchdog all non-privileged, non-exempt public records requested in both its July 23, 2019 Revised 11 Request and July 19, 2019 Request. The Department of Insurance also violated the PRA by refusing to 12 provide Commissioner Lara’s calendar in its native format in response to the July 23, 2019 Revised 13 Request, instead creating a new record summarizing cherry-picked calendar entries while apparently 14 scrubbing information it sought to conceal. 15 60. The withheld information is of significant interest to Consumer Watchdog, to the 16 members of Consumer Watchdog, and to all California consumers. 17 61. Respondents/Defendants have a clear, present, and ministerial duty under the PRA, 18 including, inter alia, Government Code section 6253, to promptly search for and produce all non- 19 privileged, non-exempted public records requested in both the July 23, 2019 Revised Request and the 20 July 19, 2019 Request. 21 62. Consumer Watchdog has a beneficial interest in the issuance of a writ of mandate, apart 22 from the public at large, in that Consumer Watchdog is a non-profit consumer advocacy organization 23 that requested the documents at issue here to increase the public accountability of elected officials. 24 Consumer Watchdog has no plain, speedy, and adequate remedy in the ordinary course of law, in that no 25 damages or other legal remedy could compensate it and its members for the harm that they and all 26 Californians will suffer if Respondents/Defendants are not compelled to immediately produce and make 27 public the requested documents. 28 19 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 SECOND CAUSE OF ACTION

2 (Violation of the California Public Records Act, Gov. Code § 6250 et seq. by Consumer Watchdog against all Respondents and Defendants) 3

4 (Declaratory Relief, Code Civ. Proc., § 1060) 5 63. Consumer Watchdog re-alleges and incorporates by reference the allegations set forth in 6 paragraphs 1 through 62 above. 7 64. An actual controversy has arisen and now exists between Consumer Watchdog and 8 Respondents/Defendants concerning the obligations and duties of Respondents/Defendants under the 9 PRA. As set forth more fully above, Consumer Watchdog contends that the type of records sought by the 10 July 23, 2019 Revised Request and July 19, 2019 Request are subject to, and must be produced pursuant 11 to, the PRA. Consumer Watchdog is informed and believes, and on that basis alleges, that 12 Respondents/Defendants contend in all respects to the contrary. 13 65. A judicial determination and declaration as to the legal obligations of 14 Respondents/Defendants is therefore necessary and appropriate in order to determine the duties of the 15 Respondents/Defendants and the rights of Californians that Consumer Watchdog represents. 16 PRAYER FOR RELIEF 17 WHEREFORE, Consumer Watchdog prays for judgment as follows: 18 1. That this Court issue a peremptory writ of mandate commanding Respondents/Defendants 19 to immediately produce copies of all non-privileged, non-exempted public records requested in both 20 Consumer Watchdog’s July 23, 2019 Revised Request and the July 19, 2019 Request, including 21 Commissioner Lara’s calendar in its native format with redactions of exempt material if appropriate. 22 2. That this Court declare that the records sought under the July 23, 2019 Revised Request 23 and the July 19, 2019 Request are of the type that must be disclosed pursuant to the PRA, and 24 Respondents/Defendants violated the PRA by refusing to disclose the responsive records in response to 25 Consumer Watchdog’s PRA requests. 26 3. That this Court award Consumer Watchdog its costs of suit herein, including out-of- 27 pocket expenses and reasonable attorneys’ fees under Code of Civil Procedure section 1021.5, 28 Government Code section 6259, subdivision (d), and any other applicable statute. 20 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1 4. That this Court grant Consumer Watchdog such other, different, or further relief as the 2 Court may deem just and proper.

3 DATE: February 18, 2020 CONSUMER WATCHDOG

4 By: 5 JERRY FLANAGAN BENJAMIN POWELL 6 LAW OFFICES OF KELLY AVILES 7 By: 8 KELLY AVILES

9 Attorneys for Petitioner/Plaintiff

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28 21 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

VERIFICATION 1 2 I, Jamie Court, declare: 3 I am the President of Consumer Watchdog, Petitioner/Plaintiff in the above-entitled action. I have 4 read the foregoing VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR 5 DECLARATORY RELIEF and know the contents thereof to be true of my own knowledge, except as to 6 those matters that are alleged on information and belief, and as to those matters I believe them to be true. 7 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and 8 correct. 9 Executed this 18th day of February, 2020 in Los Angeles, California. 10 11 12 ______13 Jamie Court 14 President, Consumer Watchdog

15 16 17 18 19 20 21 22 23 24 25 26 27 28 22 VERIFIED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF IFIED PETITION FOR WRIT OF MANDAMUS AND TAXPAYER COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

EXHIBIT 1

ENDORSED r:n.r-:o 2 SAN MATEO COUNTY

3 NOV O 4 2019 4 Clerk of the Superl~r Court By R,Jey Oomtnle 5 DEPUTY CLERK 6 Exempt from filing fees pursuant to 7 Government Code section 6103 8 9 SUPERIOR COURT OF THE STA TE OF CALIFORNIA 10 FOR TH E COUNTY OF SAN MA TEO - UNLIMITED JURISDICTION 11 12 INSURANCE COMMISSIONER OF THE Case No. 19CIV06531 STATE OF CALIFORNIA, 13 (PROPOSED] ORDER APPOINTING Applicant, INSURANCE COMMISSIONER AS 14 CONSERVATOR and RESTRAINING V. ORDERS; 15 CALIFORNIA INSURANCE COMPANY, a [Ins. Code,§ 1011] 16 California corporation, Date: November 4, 2019 17 Respondent. Time: 2:00 p.ni. Dept.: 18 19

20 21 22 23 24 25 26 27 28

Printed on Recvcfed Pa t r f PROPOSED) ORDER APPOINTING INSURJ\NCE COMMISSIONER AS CONSER VATOR AND RESTRAINING ORDERS; [PR:OPQSEB! ORDER 2 The Cali fornia Insurance Commissioner's Verified Ex Parte Appl ication for Order Appointing 3 Conservator having been filed herein, it being shown to the Court's satisfaction from said Application 4 that the Commissioner has(!) found that Cal iforn ia Insurance Company ("CIC"), a California 5 domic iled insurance company, entered into a transaction the effect of wh ich, if consummated, would 6 merge CIC into and with Cal ifornia Insurance Company II ("CIC II"), a New Mex ico dom iciled 7 insurance company without first obtaining the consent in writing of the Ca lifomia Insurance 8 Commissioner in violation of California Insurance Code Section 1215.2(a), (2) found that the factual 9 and legal conditions exist to conserve CIC pursuant to Insurance Code section l 01 1, subdivision (c), 10 and (3) established good cause to believe that the State of California would be prejudiced were it to I I provide respondent advanced notice of this proceeding in that CIC has within its authority power to at 12 any time complete the ostensible consummation of the transaction, which would have the effect ofat 13 least foifeiting CIC's certificate of authority, rendering Cal ifo nli'a policyholders ostensibly insured by 14 an out-of-state insurer without authority to transact insurance in California; and good cause appearing, 15 IT IS HEREBY ORDERED that: 16 I. The California Insurance Commissioner is hereby appointed as the Conservator of CIC 17 pursuant to section JO11, and is directed to conduct the business of CIC or so much thereof as he may 18 deem appropriate, to pay or defer payment of all proper claims and obligations against CIC accruing 19 prior to or subsequent to his appointment as Conservator, and to act in all ways and exercise all powers 20 necessary or appropriate for the purpose of carrying_out this order. 21 2. CIC, its officers, directors, agents and employees and any person that acts or purports to 22 act on its behalf of any of the foregoing shall be enjoined from taking any actions or fi ling any document with any governmental enti ty or any govenunental subdivision necessary to consummate 24 the merger of CIC into and with CIC II, to otherwise transfer the domici le of CIC from Cal iforn ia to 25 New Mexico, or to otherwise adversely affect the California Certificate of Authority of CIC. 26 3. David E. Wilson, Special Deputy Insurance Comm issioner, is appointed as Deputy 27 Conservator empowered to carry out any and all duties and exercise the authority of the Conservator 28 granted here in and the Insurance Code. Joseph B. Holloway, Jr. is appointed as Conservation

2 [PROPOSED) ORDGR APPOINTING INSURANCE COMMISSIONER AS CONSERVATOR AND RESTRAIN ING ORDERS; Manager and Scott Pearce is appointed as Conservation Supervisor empowered to carry out any and all 2 duties and exercise the authority of the Conservator and Deputy Conservator, and as may be delegated 3 by the Conservator and Deputy Conservator. 4 4. The Conservator's immunity and related protections from claims, sui ts or liabi lity 5 under applicable Jaw, including but not limi ted to Government Code section 820.2, shall apply eq ually 6 to the Deputy Conservator, Conservation Manager and the Conservation Supervisor in their capacities 7 as Receiver of CIC, their successors in office, the Conservation & Liquidation Office ("CLO"), and 8 their agents and employees. 9 5. The Commissioner as Conservator is authorized to appoint and employ special 10 deputies, estate managers, other professionals, clerks and assistants and to give each of them such 11 power and authority as he may deem necessary and authorizing the Commissioner as Conservator to 12 compensate these persons from the assets of CIC as he may deem appropriate. 13 6. The Conservator is authorized to assist CIC in addressing their Form A deficiencies 14 with the goal of obtaining Form A approval and settlement of disputes with CDI. 15 7. CIC is ordered, except upon the express written authorization of the Conservator, not to

16 cancel or otherwise terminate or attempt LO cancel or terminate any insurance policy or contract in- 17 force as of the date of this Order, and is ordered to continue to administer such in-force policies and 18 contracts in the ordinary course consistent with past practices. 19 8. Except as otherwise determined by the Conservator in his or her discretion, any 20 contract or agreemen t to provide administrative, claims, or other management services to CIC 21 necessary or appropriate for the efficient operations of CIC during the pendency of the conservation 22 shall remain in full force and effect unless rejected, modified or term inated by the Conservator in 23 writing, and unless directed otherwise by the Conservator, each such person or entity shall continue to 24 perform its respective obl igations under such contract or agreement during the pendency of the 25 conservation consistent with past practice. 26 9. The Conservator is authorized, in his or her discretion, to pay or defer payment of some 27 or all proper claims, expenses, liabilities, and obligations of CIC, in whole or in pare, accruing prior or 28 subsequent to his appointment as Conservator.

3 (PROPOSW] 0RD8R APl'()IN1'1N0 INSUR,INCE COMMISSIONER AS CONSERVATOR ,IND RF.STR1\INING ORDERS; l,

I 0. The Conservator is au thorized to assume, reject, or modify any executory contracts 2 incl uding, without lim itation, any lease, rental or utilization contract or agreement (including any 3 schedule to any such contract or agreement), and any license or other arrangement for the use of 4 computer software of business information systems, to which CIC is a party or as to which CIC agrees 5 tO accept an assignment of such contract. 6 11. The Conservator is m1thorizcd in his or her discretion to take possession of any and all 7 asse ts of CIC, including books, records, property (both real and personal), accounts, safe depos it 8 boxes, rights of action, and all such assets as may be in the name of CIC, wheresoever situated . 9 12. Title to all property and assets of CIC, designated by the Conservator in his or her 10 discretion, including deposits, securities, contracts, rights of actions, books, records, and other assets I l of every type and nature, and including both those presently in ClC's possession and those that may be 12 discovered hereafter, wheresoever situated, that are necessary or appropriate for the orderly 13 conservation of CIC is to be vested in the Conservator or his or her successor in office, in his official 14 capacity as Conservator. The Conservator is authorized to deal with such assets in his or her own 15 name as Conservator or in the name of CIC, and all persons are enjoined from interfering with 16 Conservator's possession and title to such assets. 17 13. The Conservator is authorized to maintain and invest such of Ci C's assets and funds in 18 such a maru1er as the Co nservator determines in his or her discretion is in the best interest of CJC's 19 creditors. 20 14. The Conservator is authorized to exercise all the powers of the directors, officers, and 21 managers of CIC, necessary or appropriate for the orderly conservation of CIC whose authorities are 22 suspended except as such powers may be redelegated to them in writi ng by the Conservator. 23 15. CIC, its officers, directors, agents, and employees are enjoined, except upon the express. 24 written authorization of the Conservator or as is necessary to continue to administer in the ordinary 25 course consistent with past practices any in-force insurance policies as of the date of this Order, from 26 transac ting any of the business of CIC, whether in the State of Cali fornia or otherwise, disposing of, 27 using, transferring, selling, assigning, canceling, alienating, hypothecating, or concealing in any 28 manner or any way, or assisting any person in any of the foregoing, the property or assets ofCfC, or

4 (PROPOScD] ORDER APPOINTING INSUR,\NCE COMMISSIONER AS CONSERVATOR AND RESTR,\INING ORDERS; property or assets in the possession of Cl C, of any nature or kind; including claims or causes of action, 2 until fmther order of the Court, Further, such persons arc enjoined from obstrncting or interfering with 3 the Conservator's conduct of his or her duties as Conservator. 4 16. CIC and its officers, directors, agents and employees are enjoined from issuing any new 5 or renewing any insurance policies except upon the wrinen consent of the Conservator. 6 17. All persons are enjoined, except upon the written consent of the Conservator, from 7 instituting, prosecuting, or maintaining any action at law or suit in equity, including but not limited to, 8 actions or proceedings to compel discovery or production of documents or testimony, and matters in 9 arbitration, except for matters before the California Workers' Compensation Appeals Board or 10 equivalent administrative boards in other states, against CIC, or against the Conservator, and from 11 attaching, executing upon, redeeming of or taking any other legal proceedings against any of the 12 property of CIC, and from doing any act interfering with the conduct of said business by the 13 Conservator, except after an order of this Court obtained after reasonable notice to the Conservator. 14 18. CIC and all officers, directors, agents, employees, successors, assigns, affiliates of CIC, 15 and other persons acting in co11ce1t or paiticipation with CIC shall deliver to and immediately make 16 available to the Conservator those assets, books, records, accounts, records, information, computers, 17 tapes, discs, v,ritings, other recordings of information, equipment, and other property of CIC, 18 wheresoever situated, in said persons' custody or control specified in writing by the Conservator, and 19 further, the aforesaid persons shall disclose verbally, or in vniting if requested by the Conservator, the 20 exact whereabouts of the foregoing items ifsuch items are not in the possession custody, or control of 21 said persons. 22 19. All officers, directors, trustees, employees, or agents of CIC, or any other person, firm, · 23 association, partnership, corporate pareni, holding company, affiliate, or other entity in charge of any 24 aspect of CI C's affairs, either in whole or in'pan, and including but not limited to banks, savings and 25 loan associations, financial or lending institutions, brokers, stock or mutual associations, or any parent, 26 holding company, subsidiary or affiliated corp?ration, or any other representative acting in concert 27 with CIC, shall cooperate with the Conservator in the performance of his or her duties. 28 -·

5 [PROPOSED) ORDER APPOINTING INSURANCE COMMISSIONER AS CONSERVATOR AND RESTRAIN ING ORDERS; ,,

20. The Conservator is authorized to pay all reasonable costs of taking possession of and 2 conserving CIC (including but not limited to the Conservator's pre-conservation costs in exam ining 3 CI C's financial condition, and preparing to take possession and conserve CIC, and the attorneys' fees 4 and costs incurred by the Commissioner in bringing and prosecuting this proceeding) out of the funds 5 and assets of CIC. 6 21. The Conservator is authorized to pay all reasona_blc costs of operating CIC as 7 Conservator (includ ing di rect and allocated direct costs, direct and allocated general and 8 admin istrative costs and overhead, and all other allocated costs) out of any and al l funds and assets of 9 CIC, and if there are insufficient funds, to pay for the costs out of the Insurance Fund pursuant to 10 lnsurnnce Code section I 035. 11 22. All persons who maintain records for CIC, pursuant to written contract or any other 12 agreement, shall maintain such records and deliver to the Conservator such records upon his request. 13 23. All agents of CIC, and all brokers who have done bus iness with CIC, shall make 14 remittances of all funds collected by_them or in their hands designated by the Conservator in his or her 15 discretion, directly to the Conservator. 16 24. All persons having possession of any Ii sts of policyholders of CIC shall deliver such 17 lists to the Conservator upon his or her written request and enjoining all such persons from using any ) 8 such lists or any information contained therein without the written consent of the Conservator. 19 25. The Conservator is authorized to initiate such equitable or legal actions or proceedings 20 in this or other states that the Conservator determines is in his or her discretion are necessary to ca1Ty 21 out his or her functions as Conservator. 22 26. CIC, its officers, di rectors, agents and employees are enjoined from disposing of, or 23 assisting any person in the u·ansfer or alienation of, the property or assets of CIC, until fu1iher order of 24 this Court. 25 27. All persons are enjoined, except with leave of this Court issued after a hearing in which 26 the Conservawr has received reasonable notice, from obtaining preferences, judgments, attachments, 27 or other liens, or making any levy against CIC or its assets or prope1iy, and from executing or issui ng 28 or causing the execmion or issuance of any cot111 attachment, subpoena, replevin, executi on, or other

6 [PROPOSED) ORDER APPOINflNG INSURANC£ COMMISSIONER ,IS CONSERVATOR AND RESTRAINING OR()€RS; process, for the purpose of impound ing or taking possession of or interfering with or creati ng or 2 enforcing a lien upon any property or assets ovmed or in the possession of CIC or the Conservator, 3 wheresoeve r situated, and from doing any act interfering with the conduct of said business by 4 Conservator. 5 28. All persons are enjoined, except with leave or this Co urt issued after a hearing in which 6 Conservator has rece ived reasonable notice, from accelerating the clue date of any obl igation or 7 claimed obligation; exercising any right of set-off; taking, retaining, retaking, or attempting to retake 8 possession of any real or personal property; withholding or diverting any rent or other obligation; 9 doing any act or other thing whatsoever to interfere with the possession of or management by the 10 Conservator of the property and assets, owned or controlled by CIC or in the possession of CIC, or in 11 any way interfering with the Conservator or interfering in any manner during the pendency of this 12 proceeding with the exclusive jurisd iction of this Court over CIC. 13 29 Any and all provisions of any agreement entered into by and between any th ird party 14 and CIC that provide in any mallller that selection, appointment, or retention of a conservator, receiver, 15 or trustee by any court, or entry of any order such as hereby made, shall be deemed to be or otherwise 16 operate as a breach, violation, event of default, termination, event of dissolution, event of acceleration, 17 insolvency, bankruptcy, or liquidation, shall be stayed, and the assertion of any and all rights and 18 remedies relating thereto shall also be stayed and barred, except as otherwise ordered by this Court. l 9 This Court shall retain jurisdicti.on qver any cause of action that has arisen or n,ay otherwise arise \ 20 under any such ~rovision. · '\ ' ' ·;, 21 30. All. persons: are enjoined,, from wasting the assets of CIC. ,,;-,; I 22 IT IS SO ORDERED. , . ' 23

24 Dated: November _!/_, 2019 ~£~ JUD~THE SUPERIOR COURT 25 GEORGE A. MIRAM 26 27 28

7 !PJ

EXHIBIT 2

June 4, 2019

VIA EMAIL AND OVERIGHT DELIVERY

California Department of Insurance Custodian of Records 300 Capitol Mall, Suite 1700 Sacramento, CA 95814

Email: [email protected] Tel.: (916) 492-3657

RE: Public Records Act Request

Dear Custodian of Records,

Pursuant to Government Code section 6253, subdivision (b) of the Public Records Act (“PRA”), and Article 1, section 3 of the California Constitution, Consumer Watchdog hereby requests copies of the following records:1

1. All appointment schedules, calendars, meeting logs, phone call logs, mobile phone records, and any other records relating to any meetings or phone calls (“Conferences”) between Insurance Commissioner Lara and any individuals2 who are employed by or represent the interests of one or more insurance companies or the insurance industry. This request includes but is not limited to records providing the identities of the individuals participating in the Conferences as well as records reflecting when and where the Conferences occurred.

2. All records regarding Insurance Commissioner Lara’s travel, including the individuals or entities that paid for that travel, including airfare and other transportation, hotels, meals, and entertainment.

3. All records regarding the March 21, 2019 Climate Change Petition for Rulemaking (“Climate Change Petition”)3 and the February 21, 2019 Petition for Rulemaking to ban the use of education and occupation to set insurance premiums (“Education/Occupation Petition”).4

1 As used in this letter, the term “records” includes writings and correspondence that are printed, typed, hand-written, facsimiles or computer-generated e-mail. 2 As used in this letter, the term “individuals” does not include those persons employed by the Department of Insurance (“Department”). 3 A copy of the Climate Change Petition is attached as Exhibit A. 4 A copy of the Education/Occupation Petition is attached as Exhibit B.

California Department of Insurance June 4, 2019 Page 2 of 2

Consumer Watchdog requests these records in an electronic format such as a Portable Document Format (“PDF”).

Any records withheld from production for inspection should be separately identified and should be accompanied by the claimed justification for withholding those records as required by Government Code section 6255. The justification should state the nature of the record withheld and the specific exemption under which the record is being withheld, and provide an explanation of why the public interest is served by withholding the record. We reserve the right to appeal the Department’s decision to withhold any materials.

Should you contend that a portion of a particular record is exempt from disclosure, pursuant to Government Code section 6253, subdivision (a) the exempt portion should be redacted and the remaining portion be produced for inspection.

Consumer Watchdog is prepared to pay reasonable search and duplication fees in connection with this request. However, agencies have discretion to waive fees in order to provide greater access to public records pursuant to Government Code section 6253, subdivision (e). (See North Co. Parents Org. v. California Dep’t of Educ. (1994) 23 Cal.App.4th 144, 148.) As the information that is the subject of this request is of primary benefit to the public, we ask that the Department waive all search and duplication fees.

Consistent with Government Code section 6253, subdivision (c), we expect to hear from the Department within ten days. If you have any questions regarding this Public Records Act request, please contact me at (310) 392-2632 or [email protected].

Respectfully submitted,

Jerry Flanagan

EXHIBIT A

March 21, 2019

VIA EMAIL AND OVERNIGHT MAIL

The Honorable Ricardo Lara Insurance Commissioner State of California 300 Capital Mall, Suite 1700 Sacramento, CA 95814

Re: Protect Consumers and Insurance Companies from Climate Change Petition for Rulemaking Pursuant to Government Code section 11340.6

Dear Commissioner Lara:

We write to you because insurance companies in California are facing unprecedented threats to their solvency and ability to write insurance policies throughout California due to the increase in frequency and severity of wildfires, exacerbated by climate change. The potential impacts on the insurance industry are myriad, and may be grouped into underwriting risks (property and casualty) and risks to the assets that insurers develop to fund losses and provide a return to investors. In the core business of insurance, weather and climate-related losses can affect physical assets such as buildings, business, vehicles, crops, life, and health. On the investment side of the business of insurance, the risks to the values of fossil fuel-related assets constitute transition risks. Transition risks of insurers’ investments in fossil fuel-related entities are the financial risks, including investment losses, to insurers as the world drastically reduces the use of fossil fuels. A tertiary impact on the business of insurance relates to increased loss related to litigation. The results of actions of those responsible for greenhouse-gas pollution are increasingly leading to litigation, the costs of which are often borne by insurers. The significance of this latter trend is reinforced by the ability to causally attribute climate events to human activity (Marjanac and Patton 2018).

California is the fifth largest economy in the world, and is already experiencing natural hazards that are arising from climate change. With a GDP of $2.7 trillion and a population of almost 40 million residents, much is at stake. California is the nation’s largest insurance market, with over 1,300 insurance companies collecting $310 billion in premiums annually and holding $5 trillion in assets under management (CDI September 2018). In California, as in much of the world, insurance is the grease in the wheels of the broader economy. Insurance serves an essential role of spreading risk, helping homeowners and businesses manage losses that would otherwise be crippling.

Insurance Commissioner Ricardo Lara March 21, 2019 Page 2 of 14

The increased frequency and severity of wildfires are caused by climate change. The investment and underwriting of fossil fuel-related entities and projects by the insurance industry are causally related to the exacerbation of climate change. As a result, insurance companies, and consumers face substantial fiscal and physical damages.

To ensure the solvency of the insurance industry and protect consumers in California, we request that you immediately initiate a rulemaking proceeding and promulgate emergency regulations to require all insurance companies licensed to conduct business in California to fully disclose: (1) all their investments in fossil fuel-related entities, and (2) all the fossil fuel-related companies and projects that they underwrite or otherwise insure. Acquiring this information is necessary for regulatory transparency. Transparency is the first and most important weapon in a financial regulator’s arsenal to help protect the financial solvency of insurers and the interests of consumers.

California law recognizes instances where the Commissioner may act with urgency to protect the health, safety and welfare of consumers, and the financial health and solvency of insurance companies, by authorizing the promulgation of emergency regulations (Ins. Code § 12921.7; Gov. Code § 11346.1).

I. Background – Scope of the Problem

Impact of Climate Change on Weather-related Events

Weather-related events cause approximately 90% of natural disasters and their costs in an average year (Munich re). In 2017, record-breaking global cost records for such events were $320 billion, of which $133 billion (42%) were insured. The vast majority of these impacts (93% of total insured losses) were in North America (Aon Benfield 2018). The Tubbs Fire in the Napa Valley was the costliest wildfire in the global insurance industry’s history and the largest urban conflagration (Aon Benfield 2018). These trends also establish a nexus between intensifying hazards and consumers who continue to move into wildland urban interface areas (WUI). The results are material for property insurers: global losses in 2017 reduced industry-estimated return on equity from a healthy 11% the year before to negative 4% (Swiss Re 2017).

Climate change will increase the frequency and intensity of extreme weather events (USGCRP 2017). The World Economics Forum equates the risks from climate change to those of weapons of mass destruction (WEF 2018). The failure of climate change mitigation and adaptation is ranked the fifth highest risk, pursuant to the insurance industry own information (Marsh & McLennan Companies and Zurich Insurance Group). Recent assessments have concluded that the multiplicity of simultaneous and correlated climate risks is expected to magnify current volatility levels and adversely impact credit within the insurance industry (Moody’s 2018).

Major U.S. insurers note that climate change is a risk to the property and casualty industry, as well as the life and health insurance business (Chubb 2016). “Climate-related losses could materially and adversely affect our results of operations, our financial position and/or

Insurance Commissioner Ricardo Lara March 21, 2019 Page 3 of 14

liquidity, and could adversely impact our ratings, our ability to raise capital and the availability and cost of reinsurance.” (Travelers Insurance Annual Report, SEC Form 10-K, 2014).

Wildfire damages of $16.5 billion, resulting from California’s Camp wildfire alone, accounted for the costliest catastrophe in 2018. Substantially fueled by the state’s recent droughts, the Camp wildfire graphically exposed the risks that climate change poses to the insurance industry (CDI 2018).

California wildfires coupled with the massive mudslide and debris flows that followed resulted in 56,000 insurance claims and $13.3 billion in losses in 2018, including 7,384 complete losses of insured structures, and 9,978 claims for vehicles and other miscellaneous damages. While mud slides are usually exempted from insurance coverage, where the “efficient proximate cause” is an insured hazard, such as a wildfire, then the resulting losses are insured (CDI 2018).

Counting up the insured losses from the wildfires, $12.6 billion in claims were filed as of May 2018. Over 39,000 insured homes were damaged, of which 6,885 were complete losses. About 5,000 insured non-residential buildings were damaged – of which 343 were complete losses – representing $1.6 billion in claims. In addition, claims for cars, boats, planes, and other miscellaneous equipment and structures amounted to about $350 million. In Santa Rosa alone, 3,000 homes (5% of the city’s housing stock) were lost.

There are also additional damages to public facilities, infrastructure, and crops, including 57 wineries (Hodgins 2017; Orlin and Steade 2017). The 2017 wildfires resulted in damage to a total of more than 10,800 structures, a third of which were not insured (Tierney 2018). Uninsured agricultural losses are estimated at $189 million, and diverse damages to publicly owned structures, such as schools and county office buildings, infrastructure, plus first responder and clean-up costs were absorbed by the taxpayers (Bloch 2018).

It is estimated that two million homes in California are categorized as being in a “High” or “Extreme” wildfire risk area (Verisk). Of the weather-related disasters in California in 2017, there were 43 fatalities from the wildfires, and 21 fatalities from the mudslides that followed (Dolan 2018). It is important to note that these numbers do not include the Paradise Fire.

Ancillary risk factors result from air pollution, disease transmission, increasing allergens, extreme heat, food and water supply, water quality, and environmental degradation. The World Health Organization projects 250,000 extra deaths each year due to climate change between 2030 and 2050, increasing significantly thereafter (WHO 2014). Far more cases of non-fatal illness are expected as well, and will affect insurers doing business in California. Of particular relevance in California are the consequences of heavy rains, floods, mud slides, heatwaves (CEHTP 2018; Guirguis et al. 2014), kidney disease related to increased temperatures and dehydration (Brikowski et al. 2008), and spiking hospital admissions related to respiratory health that accompanies major wildfires (UC Irvine 2008; UCSF 2017).

Insurance Commissioner Ricardo Lara March 21, 2019 Page 4 of 14

Risk to Value of Insurer Investment and Assets

Risks to the values of assets constitute transition risks and, ultimately, stranded assets. Transition risks and stranded assets will result in investment losses to insurers as the world drastically reduces the use of fossil fuels. Transition risks reflect the uncertainty of financial markets in the evolving, carbon-constrained world. “[Transition risks are] the financial risks which could result from the process of adjustment towards a lower-carbon economy. Changes in policy, technology and physical risks could prompt a reassessment of the value of a large range of assets as costs and opportunities become apparent.” (Bank of England Governor, Mark Carney, Remarks, Lloyd’s of London, September 29, 2015.)

Of particular concern to the California Department of Insurance (CDI) is whether insurers are recognizing the transitions risks their investments in fossil fuel-related entities present. Transition, and its resultant stranded assets (assets that become obsolete, nonperforming, or suffer from unanticipated or pre-mature write-downs, devaluations or conversion to liabilities), is the significant potential risk of loss that insurers and their investors will incur when nations, states, local governments, private companies, consumers, and markets sufficiently restrict or reduce the use of fossil fuels, or that market forces alone will cause the devaluation of fossil fuel- related entities. This obviously presents a risk to insurer investments linked to those entities. Insurance companies need to recognize and address potentially significant climate-related risks facing their investments in vulnerable fossil fuel-related entities.

Significant national, state, and local government efforts are also pushing a transition to a low carbon-intensive economy. This effort includes the various commitments made by nearly all national governments in the world as a part of the United Nations COP 21 Agreement, and state and local commitments made in association with COP 21. It has been projected that in order for countries to meet the COP 21 targets of not exceeding a two degrees Celsius temperature rise, more than 80% of coal reserves, a third of oil reserves, and half of gas reserves cannot be used between 2010 and 2050 (McGlade and Ekins 2015).

The fact that California’s admitted insurers hold $5 trillion in investments under management, including a significant amount of fossil fuel-related investments, is one of the reasons that in 2016, the CDI conducted a voluntary survey of insurers doing business in California to find out which insurers had investments in fossil fuel-related entities. The survey found that the insurers who responded had $528 billion in fossil fuel-related investments, which included investments in coal, oil, gas, and in utilities that rely on fossil fuels to generate electricity. The responding insurers reported holding a total of $105 billion in investments in thermal-coal enterprises (CDI 2017).

The current decreasing cost of renewable energy threatens the value of the insurance industry’s carbon investments.

• Renewable energy has become more competitive, with solar costs dropping 85% from 2008 to 2016 (Houser et al. 2018) and wind costs falling 36% in that same period (ClimateNexus 2017). Solar is already at least as cheap as coal in the United States,

Insurance Commissioner Ricardo Lara March 21, 2019 Page 5 of 14

Germany, Australia, Spain, and Italy, and is expected to drop another 66% by 2040. By 2021, solar is projected to be cheaper than coal in China, India, Mexico, the U.K., and Brazil as well. The cost is expected to continue to decline as technology improves (BNEF 2017). • Over the last decade, demand for coal has dropped dramatically. Coal has gone from generating nearly half of U.S. electricity to approximately 30%, a share that continues to decline. This downturn in demand has directly affected companies mining and selling coal. Three dozen U.S. coal companies went bankrupt in three years (SNL 2015). • Utilities in the United States are shutting down thermal coal power plants before the end of their economic lifetimes, and none are building any new ones. • Major banks have ceased or reduced lending to fund new coal infrastructure (i.e., Citigroup, Bank of America, Wells Fargo & Company, and Morgan Stanley) (Nussbaum 2015). • Global insurers such as AXA, Allianz, Aegon, and Swiss Re announced that they are divesting or not making new investments in thermal coal (Ferguson 2017; Insurance Journal 2018). • After the California State Teachers Retirement System and the California Public Employees’ Retirement System, the largest pension funds in terms of assets in the United States, lost a combined $5.1 billion in oil, gas, and coal investments in 2014-2015 (Trillium 2015), the state Legislature directed them to consider divesting from thermal coal. • The Dow Jones U.S. Coal Index decreased 92.9% from April 1, 2011 through June 20, 2017. • Some European insurers have ceased to write policies for companies whose profits depend on coal. Allianz plans to no longer underwrite individual coal-fired power plants or coal mines, and plans to phase out all underwriting to coal interests by 2040 (Jergler 2018). Swiss Re no longer underwrites mining companies that derive more than 30% of revenues from thermal coal or utilities that generate 30% of their electricity from thermal coal (Insurance Journal 2018).

These and other developments create risk that investments in coal and other fossil fuels may become “stranded assets” of diminishing value. Some experts have stated that life and annuity insurers have the largest exposures, given their “buy-and-hold” philosophies (Messervy and McHale 2016).

Insurer Underwriting Risk from Fossil Fuel Projects

The insurance industry has declined to disclose to what extent they are underwriting/ insuring, or investing in fossil fuel-related projects, claiming that information regarding their coverages are trade secrets. So, the information available regarding this area of financial exposure related to the financial health and solvency of insurance companies doing business in California remains unknown. This is yet another reason for the urgent need for regulations requiring insurers to disclose such investments or activities to the CDI and the public. Transparency is critical to ensure the solvency of an insurance company and protect consumers in our evolving climate-changing environment.

Insurance Commissioner Ricardo Lara March 21, 2019 Page 6 of 14

The energy firm Enbridge’s situation is just one example of the downside risk to the solvency of insurers underwriting fossil fuel-related projects; as well as the great risk to the health, safety and welfare of the state’s citizens and consumers.

The Minnesota Department of Commerce reviewed Enbridge’s insurance policies and determined that Enbridge does not have adequate insurance to protect the public from damages related to accidents, such as crude oil spills. This would make taxpayers responsible for paying for the cleanup of any pipeline accidents. Upon review of their August 31, 2018 Supplemental Filing to the Minnesota Public Utilities Commission, the department concluded that the policies do not cover damages from crude oil spills to any significant degree, if at all. The agency said Enbridge’s insurance includes significant exclusions related to damages caused by crude oil spills (Associated Press December 21, 2018).

Dane County, Minnesota, had pursued special insurance upon the recommendations of an independent consultant, which were due in part to Enbridge’s legal battle with an insurer that refused to pay cleanup costs from a 2010 Kalamazoo River oil spill in Marshall, Michigan. The climate change action group 350 Madison argued that Enbridge may not be as financially sound in the future as it is now. If the fossil fuel industry and the oil sector start going bankrupt, they will not have the money even if they voluntarily wanted to clean up the mess that they cause in these kinds of major accidents. (Peter Andersen, 350 Madison.)

Anderson also called for transparency on Enbridge’s insurance policies, noting that information about its coverage had been heavily redacted. Enbridge designated portions of its coverage as trade secrets in its response to the Minnesota regulator. As insurers have claimed to the CDI, Enbridge argued that it would be “detrimental” to the company because it would provide “proprietary” information to competitors. Thus, as in California, insurer and insured both claim that their insurance coverage information is privileged and disclosure would negatively impact their ability to compete, and hamper their future negotiations or claims (Associated Press December 21, 2018).

However, disclosure provides the necessary transparency that would allow the Insurance Commissioner to properly review, regulate, guide, advise and ensure that insurance companies are solvent and consumers are adequately protected in the new reality of a climate-changing environment. Timely regulatory oversight activities are also critical in protecting consumers from foreseeable and avoidable harm, as evidenced by the recent Enbridge event in Ohio.

“On January 28, 2019, an explosion of an Enbridge natural gas pipeline in Ohio created a fireball of flame and damaged homes, prompting the evacuation of nearby residents.” (Reuters, January 28, 2019.)

Solvency Issues and Financial Risks for Insurance Companies

In November of 2018, the CDI was forced to take over Merced Property and Casualty (Merced), and place it under the conservancy of the California Insurance Guarantee Association (CIGA), because Merced was insolvent, being unable to pay all outstanding claims related to

Insurance Commissioner Ricardo Lara March 21, 2019 Page 7 of 14 wildfire losses in 2018. (http://www.insurance.ca.gov/0250-insurers/0300-insurers/0100- applications/ci/index.cfm)

According to CDI information, insurers doing business in California have approximately $528 billion in fossil-fuel-related investments in various sectors and asset classes. Adverse impacts on the climate and resultant competitive risks from clean energy technologies in combination with an adverse economic and regulatory environment can present financial uncertainties for these investments. (http://www.insurance.ca.gov/0250-insurers/0300- insurers/0100-applications/ci/index.cfm)

Given the unprecedented scale of recent wildfires, and the insolvency of Merced, the CDI is currently conducting additional detailed reviews of every property insurer domiciled in California to make sure they are properly managing their exposures. (http://www.insurance.ca.gov/0250-insurers/0300-insurers/0100-applications/ci/index.cfm.)

Underscoring the many ways that the Insurance Commissioner needs specific insurance investment and underwriting information relating to climate change from insurance companies, in early January of 2019, three insurers filed lawsuits against Pacific Gas & Electric (PG&E), whose power lines have been cited as the cause of the Camp wildfire. PG&E’s potential wildfire liabilities from 2017 and 2018 are estimated at more than $30 billion. On January 14, 2019, PG&E announced that it would file bankruptcy.

Insurers who hold $4.1 billion of PG&E’s $18 billion debt will pay a heavy price for the PG&E bankruptcy. Clearly, the PG&E example further evidences the urgent need for insurers to realign their risk management and underwriting strategies, in order to address escalating climate risks. Such a realignment requires guidance from you, the state insurance regulator, to reconcile insurance investments and underwriting strategies for the future.

Potential Legal Costs to Insurers

Climate changes also precipitate a diversity of litigation risks, including claims for damages against producers of fossil fuels, other business interests found to be inadequately prepared to avert the impacts of climate change, or insurers themselves over disputed contractual and liability obligations.

Individuals and local governments in the United States have sued fossil fuel companies, electricity generators, and automobile manufacturers seeking compensation for the damages caused by climate change-induced sea-level rise, extreme storms, and more that are linked to emissions they generate.

The acts of those responsible for greenhouse-gas pollution are increasingly leading to litigation, which, inevitably, involves insurers. The significance of this latter trend is reinforced by the ability to show the causal relationship between climate events and human activity (Marjanac and Patton 2018).

Insurance Commissioner Ricardo Lara March 21, 2019 Page 8 of 14

A number of new lawsuits have been filed in the United States between 2017 and 2018. In this new litigation, the plaintiffs are all local governments, while the defendants are all fossil fuel companies and their liability insurers. While not uniform in underlying facts or legal theories, these cases share a common thread of public-scale property and infrastructure damages and claims made under state law. All of these cases are in-progress, and dismissal, removal, appeal, or other developments may take place. In California alone:

• People of State of California v. BP (N.D. Cal., Docket No. 3:17-cv-06011). The cities of San Francisco and Oakland sued five oil and gas companies based on state nuisance law. The federal district court dismissed the suit in late June 2018, on grounds that the plaintiffs’ claims were displaced by the Clean Air Act as well as separation- of-powers and foreign policy concerns.

• County of Santa Cruz v. Chevron (N.D. Cal., Docket No. 5:18-cv-00450). The City and County of Santa Cruz sued 29 fossil fuel companies for damages related to nuisance, trespass, failure to warn, and negligence.

• County of San Mateo v. Chevron (N.D. Cal., Docket No. 3:17-cv-04929-MEJ). The counties of San Mateo and Marin and the City of Imperial Beach have sued fossil fuel companies under nuisance, negligence, strict liability, and trespass standards. Insurers may not only experience transition losses on their investments in these fossil fuel entities, they may also become liable for unanticipated legal payouts.

II. Regulations Are Urgently Needed to Protect the Public and Insurer Solvency

The rationale behind insurance regulation is to promote beneficial conduct and competition, and to prevent destructive or harmful conduct and competition in various areas that may lead to insurer insolvency and consumer harm. One of the key reasons for insurance regulation of the financial and investment side of the business of insurance is to prevent conduct, business practices, and competition that may cause insurers to go out of business, leaving consumers unable to collect on their claims.

Insolvency regulation has historically been a primary focus of insurance regulation. After many insolvencies in the 1980s, state regulators and the National Association of Insurance Commissioners (NAIC) enacted risk-based capital standards and implemented an accreditation program to help identify and prevent future insolvencies (Consumer Federation of America November 14, 2005). In 1988, California voters enacted Proposition 103, erecting a system of strict rate regulation infused with transparency to ensure a stable and reliable insurance marketplace aimed at protecting consumers and taxpayers.

Climate change threatens the basic functioning of insurance markets (CDI Report: Trial by Fire.) “Increasing transparency makes markets more efficient, and economics more stable and resilient.” (Michael Bloomberg, Final Report, Task Force on Climate-related Financial Disclosures, 2017.)

Insurance Commissioner Ricardo Lara March 21, 2019 Page 9 of 14

The continued investing in climate altering fossil fuel-related entities are unnecessary risks to the values of U.S. insurance company assets constituting transition risks and stranded assets. These transaction risks and stranded assets will result in investment losses to insurers as the world drastically reduces the use of fossil fuels. Transition risks also reflect the uncertainty of financial markets in the evolving, carbon-constrained world.

Immediate, imminent, and quantifiable harm to consumers and insurers from the impact of climate change makes clear the urgent need for the California Insurance Commissioner to help insurers address fossil fuel-related climate risks to their investments and solvency.

The CDI has previously sought to acquire fossil fuel-related investment and underwriting information from insurance companies through the Climate Risk Carbon Initiative (http://www.insurance.ca.gov/0250-insurers/0300-insurers/0100-applications/ci/index.cfm). However, CDI met with substantial opposition. The insurance industry’s main argument was that the Insurance Commissioner had exceeded his authority to ask for such information, no matter how imperative the reason, because there was no regulation authorizing the Commissioner to specifically request such information.

The CDI launched the Climate Risk Carbon Initiative in January 2016, to evaluate the degree to which the investments of California insurers might be impacted by the financial risks of climate change. The Initiative includes two parts. First, all insurance companies doing business in California are asked to voluntarily divest from thermal coal. Second, CDI asked 672 insurers with over $100 million in annual premiums (out of over 1300 insurers) doing business in California to disclose their investments in coal, oil, and natural gas companies. This request for information related to fossil fuel investments met with fierce legal and legislative threats from insurers, and Oil, Gas, and Coal Interests, intent on calling a halt to the Climate Risk Carbon Initiative (Center for International Environmental Law August 7, 2017).

The threats of legal action began in June 2017, in a letter from Oklahoma Attorney General Mike Hunter, eleven co-signing state Attorneys’ General from Alabama, Arkansas, Indiana, Louisiana, Missouri, Montana, North Dakota, Texas, Utah, West Virginia and Wyoming, and Kentucky Governor Matt Bevin. The letter alluded to Commissioner Jones acting beyond his portfolio, publicly shaming insurance companies, targeting energy companies with a significant presence in their states, and violating the Commerce Clause of the U.S. Constitution (Center for International Environmental Law August 7, 2017). “They sent their [threatening] missive [that] closed with an almost Trumpian threat to sue: ‘If you continue to call for divestment and require discriminatory disclosures of fossil fuel investments,’ they wrote, ‘we will be forced to consider the legal areas of relief available.’” (Michael Hiltzik, Los Angeles Times June 21, 2017). Oklahoma Attorney General Mike Hunter also said California’s policies, which require insurance companies to annually disclose their carbon-based investments as part of the National Association of Insurance Commissioners (NAIC) Climate Disclosure Survey that’s been ongoing since 2011, including investments in oil, gas and coal, will harm the energy industry (Insurance Journal May 8, 2018). Regardless, beginning in 2019, the NAIC is considering whether to

Insurance Commissioner Ricardo Lara March 21, 2019 Page 10 of 14

discontinue this voluntary activity, effectively allowing insurance companies to not disclose any fossil fuel-related information.

In addition to threats of legal action, there have been recent legislative efforts to limit the California Insurance Commissioners’ discretion to regulate insurance markets. At the same time that the Oklahoma AG’s letter threatened legal action over the Climate Risk Carbon Initiative, Senate Bill 488 (Bradford 2018), which died on the suspense file in the appropriations committee, was amended with language to limit the Commissioner’s ability to issue the data calls for the disclosures that would populate the insurers’ investment database (Center for International Environmental Law August 7, 2017). Corporate fossil fuel special interests have been emboldened by the Trump administration’s intent on reversing environmental protections and climate action. Senate Bill 488 was originally intended to add veteran and lesbian, gay, bisexual, and transgender (LGBT) business enterprises to the entities for which reporting by insurance companies would be required (Center for International Environmental Law August 7, 2017). Thus, those who intend to stymie action on climate disclosure inserted highly contentious language into an otherwise admirable bill. Not only does this effort seek to roll back progress on climate action to appease corporate interests, it does so by inserting poison pill language into a bill otherwise worth passing. This effort to legally restrict the Commissioner’s power to regulate is persistent and insidious. Similar language had been added to two earlier bills (Assembly Bill 566 Ridley- Thomas and Assembly Bill 601 Ridley-Thomas), which also died on the suspense file in the appropriations committee (Center for International Environmental Law August 7, 2017). The promulgation of specific mandatory regulations authorizing the CDI to require all 1300 insurance companies doing business in California to disclose all fossil fuel-related investments and underwriting of fossil fuel-related projects, instead of a periodic data call, is needed: (1) to prevent any potential institutional, administrative, legal or legislative opposition; (2) to prevent unnecessary and dangerous delays in receipt of such information; and (3) to ensure that the Insurance Commissioner may enquire, follow-up, and effectively regulate the insurance industry in this evolving, climate-changing environment for all consumers.

We believe that to protect consumers against the insolvency of insurance companies conducting business in California, insurers must disclose their interest in, and underwriting of, fossil fuel-related entities, in order to recognize and be able to address potentially significant climate-related risks facing their investments and insured risks in fossil fuel-related entities and projects.

In order to provide insurers with the necessary guidance related to investments in fossil fuel-related entities and projects, and to what extent those investments may impact their ability to protect consumers and their access to insurance, and to ensure the solvency of insurance companies, CDI will first need to acquire specific information from insurance companies to know which companies, and to what extent those companies invest in, and underwrite the projects of, fossil fuel-related entities.

Insurance Commissioner Ricardo Lara March 21, 2019 Page 11 of 14

For all these reasons, it is important for insurance companies, insurance regulators, and the public to better understand the scope of insurer investments in fossil fuels, the scope of their transition risk and their underwriting of fossil fuel-related projects.

III. Authority for Promulgating Emergency Regulations

We believe that it is imperative that the Insurance Commissioner adopt regulations as soon as possible, authorizing him to acquire comprehensive fossil fuel-related investment and underwriting information from insurance companies. As stated above, the Commissioner has the authority to adopt emergency regulations to protect the health, safety and welfare of consumers, and the financial health and solvency of insurance companies. (Ins. Code § 12921.7; Gov. Code § 11346.1.)

IV. Authority for Petition and Rulemaking

The undersigned organizations submit this Petition pursuant to Government Code section 11340.6, which provides that “any interested person may petition a state agency requesting the adoption, amendment, or repeal of a regulation.”

Last year, as a California state senator, you recognized the myriad of problems that climate change presents to the insurance industry and consumers, and sponsored legislation (SB 30 (Lara) 2018) that requires the Insurance Commissioner to convene a working group to identify, assess, and recommend regulations to reduce the risks of climate change related to catastrophic events, create incentives for investments, and provide mitigation incentives to lessen exposure and reduce climate risks to public safety, property, utilities, and infrastructure. Your legislative measure also contained specific legislative findings and declarations noting that much of California has increasing exposure to climate-related events; that mechanisms exist to mitigate damage from climate-related events; and innovative insurance opportunities may exist to reduce the exposure to insurers and consumers. (Ins. Code § 12922.5.)

It is clear that the Insurance Commissioner has substantial and broad authority under a myriad of provisions of the Insurance Code to require insurance companies doing business in California to submit to the Commissioner and the public any information the Commissioner deems necessary to know, comprehend, analyze, and make recommendations, judgments and orders to ensure the financial stability and solvency of insurers, and may promulgate regulations he deems necessary to accomplish his statutory responsibilities. The Commissioner’s broad- ranging statutory authority to adopt the proposed regulations includes, but is not limited to, the following sections of the Insurance Code.1

1 Note this is not a comprehensive list of every specific section of the Code that affords the Commissioner authority to regulate and obtain information from insurance companies regarding their financial and underwriting risks in each of the lines impacted by climate change, including personal and commercial property-casualty, life and health, surplus lines, workers’ compensation, and title, among others. Consumer Watchdog is happy to provide further legal

Insurance Commissioner Ricardo Lara March 21, 2019 Page 12 of 14

As Insurance Commissioner, you have both the authority and the responsibility to take such actions as are necessary to protect California consumers and to obtain full compliance with the Insurance Code and other California laws regulating the business of insurance. (Ins. Code § 12921(a).)

Prior to admission to conduct business in California, every insurer is required to “file with the commissioner a certified copy of its last annual statement or a verified financial statement exhibiting its condition and affairs.” (Ins. Code § 706.)

All insurers engaged in the business of insurance in California are required to make and file annually with the Commissioner, “in the number, form, and by the methods prescribed by the commissioner, statements exhibiting [their] condition and affairs”, as well as, any supplemental statements “covering such matters dealt with in such annual statements as the commissioner designates”, and “at such intervals as may be prescribed by the commissioner prescribes.” (Ins. Code §§ 900, 902, emphasis added.)

The Commissioner has broad authority to conduct examinations of the business and affairs any admitted insurer (Ins. Code § 730), and persons and entities providing health coverage (Ins. Code § 740).

The Commissioner is required to make an annual report to the Governor of California, the Legislature, and to the Senate and Assembly insurance committees that contains a statement and synopsis of the reports which have been filed in CDI and “showing, generally, the condition of the insurance business and interests in this state, and other matters concerning insurance.” (Ins. Code § 12922.) The Commissioner necessarily may have access to any information deemed necessary to complete this annual report.

Workers’ compensation insurers are required to file annual reports “in a form and manner prescribed by the commissioner” and the Commissioner may take pre-emptive action when he “determine[s] that there has been a material change in the insurer’s ultimate liability for future payments” to fix the deposit amounts the insurers are required to make to provide protection for the payment of claims to workers at an amount he “deems sufficient to secure the payment of the insurer’s ultimate obligations.” (Ins. Code § 11694.)

Underwritten title companies must file quarterly financial statements on forms prescribed by the Commissioner, and any “supplemental accounting and financial information when the commissioner deems it to be necessary” (Ins. Code § 12389.4), and the Commissioner has the authority to adopt rules and regulations to maintain the solvency of title insurance companies. (Ins. Code § 12389(h).)

authority for the adoption of the proposed regulations once a rulemaking proceeding is commenced.

Insurance Commissioner Ricardo Lara March 21, 2019 Page 13 of 14

As to property casualty insurance, California courts have long recognized that the Commissioner has the broad and necessary authority to adopt regulations to implement and enforce the requirements of voter enacted Proposition 103 (Ins. Code § 1861.01 et seq.) relating to insurers’ rates and underwriting practices. (Calfarm Ins. Co. v. Deukmejian (1989) 48 Cal.3d 805, 824.) Given the impact of insurers’ investment and underwriting practices on insurance rates, and the Commissioner’s duty to ensure that rates are neither excessive nor inadequate (Ins. Code § 1861.05(a)), it is imperative that the Commissioner and the public have the necessary information to evaluate insurers’ fossil fuel-related investments and underwriting risks. Indeed, the Commissioner is empowered to require insurers to provide “such other information” as he may need to evaluate insurers’ rates (Ins. Code § 1861.05(b)).2 And in order to carry out the fundamental goals of Proposition 103 to foster public participation in the ratemaking process (State Farm v. Garamendi, (2004) 32 Cal.4th 1029, 1045; Ins. Code §§ 1861.05(c), 1861.10(a)), ensure that insurance is fair, available, and affordable for all Californians, and hold the insurance commissioner accountable (Prop. 103, § 2 [uncodified]), section 1861.07 requires all information submitted to the Commissioner pursuant to the initiative to be made available to the public.

V. Conclusion

As California’s newly elected Insurance Commissioner, you have the ability and responsibility to take immediate action to ensure the solvency of the insurance industry and to protect consumers in California from the exacerbation of climate change risks linked to insurers’ investment in and underwriting of fossil fuel-related entities and projects. We look forward to your response to this Petition within thirty days, as required by Government Code section 11340.7, and to working with you on these regulations.

Sincerely,

Pamela Pressley Michael Mattoch Consumer Watchdog Consumer Watchdog

1000 Grandmothers for Future Generations Avaaz 350 Bay Area Azul 350 Chico Bay Area-System Change not Climate 350 Conejo/San Fernando Valley Change 350 Maine Beyond Extreme Energy 350 Silicon Valley Bold Alliance 350 South Bay Los Angeles California Environmental Justice Alliance 350.org Californians Against Fracking and Dangerous 350 Marin Drilling

2 More broadly, Proposition 103 subjects the business of insurance “to the laws of California applicable to any other business.” (Ins. Code § 1861.03.)

Insurance Commissioner Ricardo Lara March 21, 2019 Page 14 of 14

Alameda County Interfaith Climate Action Center for Biological Diversity Network Center for International Environmental Law Amazon Watch ClientEarth Asian Pacific Environmental Network Climate Hawks Vote Climate Resolve No Coal Alliance Coalition for Clean Air No Coal in Oakland Communities for a Better Environment (CBE) No Coal in Richmond Connecticut Citizens Action Group No Coal Vallejo Courage Campaign Oil Change International Divest Invest Presente.org Earthworks Public Citizen Filipino/American Coalition for Environmental Rainforest Action Network Solidarity (FACES) Rootskeeper Food & Water Watch San Francisco Baykeeper Fossil Free California Sierra Club California Fox Valley Citizens for Peace & Justice SoCal 350 Climate Action Friends of the Earth U.S. Stand.earth Fundacja “Rozwój TAK - Odkrywki NIE” SumOfUs.org Greenaction for Health and Environmental Justice Sunflower Alliance Greenpeace Sunrise Project Indivisible South Bay LA Sustainable Energy & Economy Network Market Forces urgewald Movement for a People’s Party Waterkeeper Alliance

PROOF OF SERVICE 1 2 State of California, City of Los Angeles, County of Los Angeles

3 I am employed in the City of Los Angeles and County of Los Angeles, State of California. I am over the age of 18 years and not a party to the within action. My business address is 6330 San Vicente 4 Blvd., Suite 250, Los Angeles, California 90048, and I am employed in the city and county where this service is occurring. 5 6 On March 21, 2019, I caused service of true and correct copies of the document entitled

7 PROTECT CONSUMERS AND INSURANCE COMPANIES FROM CLIMATE CHANGE: PETITION FOR RULEMAKING PURSUANT TO GOVERNMENT CODE SECTION 11340.6 8 upon the persons named in the attached service list, in the following manner: 9

10 1. If marked HAND DELIVERED, by personally delivering copies to the person served at the listed address. 11 2. If marked EMAIL, by electronic mail transmission this date to the email address stated. 12

13 3. If marked U.S. MAIL or OVERNIGHT, by placing this date for collection for regular or overnight mailing true copies of the within document in sealed envelopes, addressed to each of the persons 14 so listed. I am readily familiar with the regular practice of collection and processing of correspondence for mailing of U.S. Mail and for sending of Overnight mail. If mailed by U.S. 15 Mail, these envelopes would be deposited this day in the ordinary course of business with the U.S. Postal Service. If mailed Overnight, these envelopes would be deposited this day in a box or 16 other facility regularly maintained by the express service carrier or delivered this day to an 17 authorized courier or driver authorized by the express service carrier to receive documents, in the ordinary course of business, fully prepaid. 18 4. If marked FAX SERVICE, by fax transmission this date to the FAX number stated to the 19 person(s) named. Based on an agreement of the parties to accept service by fax transmission, I faxed the documents to the persons at the fax numbers listed below. No error was reported by the 20 fax machine that I used. A copy of the record of the fax transmission which I printed out is 21 attached. I declare under penalty of perjury that the foregoing is true and correct. Executed on March 21, 22 2019 at Los Angeles, California. 23

24 ______Kaitlyn Gentile 25 26 27 28 1

PROOF OF SERVICE

Service List 1

2 The Honorable Ricardo Lara FAX Insurance Commissioner U.S. MAIL 3 California Department of Insurance OVERNIGHT MAIL 300 Capital Mall, Suite 1700 HAND DELIVERED 4 Sacramento, CA 95814 EMAIL 5 6 Geoff Margolis FAX Deputy Commissioner and Special Counsel U.S. MAIL 7 California Department of Insurance OVERNIGHT MAIL 300 Capitol Mall, 17th Floor HAND DELIVERED 8 Sacramento, CA 95814 EMAIL Tel. (916) 492-3574 9 Fax (916) 445-5280 10 [email protected]

11 Edward Wu FAX 12 Staff Counsel and Public Advisor U.S. MAIL Office of the Public Advisor OVERNIGHT MAIL 13 California Department of Insurance HAND DELIVERED 14 300 South Spring Street, 12th Floor EMAIL Los Angeles, CA 90013 15 Tel. (213) 346-6635 Fax (213) 897-9241 16 [email protected] 17

18 Michael Peterson FAX Deputy Commissioner on Climate and U.S. MAIL 19 Sustainability OVERNIGHT MAIL California Department of Insurance HAND DELIVERED 20 300 Capitol Mall, 17th Floor EMAIL 21 Sacramento, CA 95814 [email protected] 22

23 Tony Cignarale FAX Deputy Commissioner, Consumer Services & U.S. MAIL 24 Market Conduct OVERNIGHT MAIL 25 California Department of Insurance HAND DELIVERED 300 South Spring Street, 12th Floor EMAIL 26 Los Angeles, CA 90013 [email protected] 27 28 2

PROOF OF SERVICE

EXHIBIT B

February 21, 2019

The Honorable Ricardo Lara Insurance Commissioner State of California 300 Capital Mall, Suite 1700 Sacramento, CA 95814 VIA OVERNIGHT MAIL AND EMAIL

Re: Stop Discriminatory Auto Insurance Overcharges Petition for Rulemaking Pursuant to Government Code section 11340.6

Dear Commissioner Lara:

We write to you because insurance companies in California are improperly utilizing a person’s occupation and education to set auto insurance premiums. The use of these unauthorized rating factors increases the cost of insurance for lower wage, less-educated and blue-collar California motorists and is a direct violation of Proposition 103. To end this discriminatory and unlawful practice, we request that you immediately initiate a rulemaking proceeding and promulgate an amendment to the Proposition 103 Automobile Rating Factor regulations (California Code of Regulations, title 10 (“10 CCR”), section 2632 et seq.) to prohibit auto insurance companies from surcharging motorists based on their occupation, education level, or any generic classification pertaining to occupation or education, many of which are thinly veiled surrogates for wealth, ethnicity and race.

Companies with at least seven of the ten largest auto insurance groups in California – including Farmers, GEICO, Progressive, AAA, Allstate, Mercury, and Liberty Mutual – surcharge drivers based on their occupation and education level. Attached is direct evidence of the financial impact of the unlawful use of occupation and education as rating factors. Most glaringly, working people with regular jobs are paying higher auto insurance premiums so that doctors, engineers and other high-income wage earners can pay less. For example, a basic limits policy1 for two drivers with the same driver safety record, and everything else being equal:

• Farmers Insurance charges a factory worker a 14.5% higher annual premium than either an accountant or a physician ($1,523 vs. $1,330).2 (Exh. A) • Progressive Auto Insurance charges a factory worker 6.3% more in annual premiums than an attorney or a physician ($878 vs. $826). (Exh. B) • GEICO charges a factory worker 14.7% higher annual premiums than the same driver who is a corporate CEO ($977 vs. $852). (Exh. C)

1 Includes bodily injury/property damage liability ($15K/$30K/$5K) and uninsured/underinsured motorist coverages ($15K/$30K). 2 Includes medical payments ($1K) coverage in addition to basic limits bodily injury/property damage liability and uninsured/underinsured motorist coverage.

Insurance Commissioner Ricardo Lara February 21, 2019 Page 2 of 7

Working people without college degrees are similarly paying more. For example, Progressive Auto Insurance charges an office manager with a high school diploma a 6.3% higher annual premium than the same driver with the same occupation who has an undergraduate degree ($878 vs. $826) (Exh. D). AAA charges a driver who is not a member of a college/university alumni association an 8.1% higher annual premium than a driver who is a member of an alumni association ($1,017 vs. $941) (Exh. E).

These recent premium quotes, obtained by Consumer Watchdog, support the findings of a national study by the Consumer Federation of America (CFA), which determined that “some major auto insurers charge higher rates to drivers with less education and lower-status jobs,” and concluded that “auto insurers are discriminating on the basis of income and race” – including in California. For example, GEICO was found to charge a factory worker in Oakland, California with a high school degree 33% more than an executive with a college degree with the same driver safety record, and everything else being equal. Liberty Mutual was found to charge a factory worker 20% more than an executive ($1074 vs. $892). (Exh. F, “Major Auto Insurers Charge Higher Rates to High School Graduates and Blue Collar Workers: National Consumer Survey Reveals that Large Majorities Reject the Use of Education and Occupation in Setting Auto Insurance Rates,” July 22, 2013, p. 1, 2.) “States should prohibit the use of these demographic factors that bear no logical relation to insurer risk,” CFA concluded.

Most insurance companies do not disclose how many people are impacted by their education and occupation surcharges. Farmers’ rate filings approved in October 2018, however, do disclose data about average premiums by coverage and number of drivers we can use to extrapolate the approximate cost per year to Californians of these discriminatory surcharges by this one company.

The prior approval rate template submitted by Farmers for drivers with its “Regular” (non-professionals) program proposed an average base premium of $815 for bodily injury/property damage liability and uninsured motorist coverages for approximately 1,264,400 projected drivers. It proposed an average base premium of $715.79 for the same coverages for approximately 431,104 drivers in its “Business and Professionals Group I” program (Exh. G). That is to say that the approximately 1.2 million regular drivers insured by Farmers each pay on average $99.21 more per year than the higher-income professionals in the Business and Professions Group I program. Collectively, that overcharge amounts to approximately $125,441,124 a year based solely on occupation.

These unfair surcharges drive up the cost of insurance for people who can least afford it. They also skirt civil rights protections to allow insurers to charge non-white, lower wage drivers more. Take for example California’s approximately 2.5 million undocumented immigrants.3 Most are from Latin American countries and work disproportionately in low-paying industries including agriculture, child care, restaurants, hotels and construction.

In 2013, the legislature enacted AB 60 giving undocumented immigrants the right to obtain drivers licenses in California. By April 2018, according to the California Department of

3 Public Policy Institute of California, “Undocumented Immigrants in California,” March 2017. https://www.ppic.org/content/pubs/jtf/JTF_UndocumentedImmigrantsJTF.pdf

Insurance Commissioner Ricardo Lara February 21, 2019 Page 3 of 7

Motor Vehicles, more than 1 million individuals had obtained licenses under the law. Yet California also mandates all drivers have auto insurance coverage. To drive legally and prevent seizure of their vehicles, and to protect other drivers on the road, those million new drivers must have access to affordable insurance.

The average basic liability insurance premium in California was $520.81 in 2016.4 Drivers with GEICO pay 14.7% more a year for not having a high-paying job. If one million newly-licensed drivers with low-wage jobs sought insurance coverage from GEICO, they would be overcharged $75,517,450 a year. This financial impact is borne by those drivers who are least able to afford it.

Undocumented drivers are, of course, only some of the millions of drivers impacted by this discriminatory practice. In 2017, just 32.6 percent of Californians over the age of 25 had a bachelor’s degree or higher. That number falls to 12.2 percent of Latinx and 24 percent of black Californians with a bachelor’s degree or higher.5

Communities of color in California also earn less and hold less wealth overall and thus bear a disproportionate burden from these surcharges. The California Senate Office of Research notes, for example, that, “for 2010-14, Latinos tended to earn less than non-Latinos and were underrepresented among higher income brackets, overrepresented at lower income brackets, and more likely to live in poverty.”6 White households in Los Angeles in 2014 had a median net worth of $355,000. In comparison, Mexican and African-American households had a median wealth of $3,500 and $4,000, respectively.7

A large percentage of drivers in California from lower-income communities of color thus pay more to fund discounts for a small cadre of college-educated, well-paid professionals. They should not, as the use of these characteristics is already illegal in California.

Proposition 103 Bars the Use of Unapproved Rating Factors

Prior to Proposition 103, “‘California ha[d] less regulation of insurance than any other state, and in California automobile liability insurance [was] less regulated than most other forms of insurance.’” (20th Century Ins. Co. v. Garamendi (1994) 8 Cal.4th 216, 240, quoting King v. Meese (1987) 43 Cal.3d 1217, 1221.) In particular, automobile insurance companies were free to set rates by whatever method they chose, often setting premiums based upon personal characteristics beyond the control of the applicant, or on factors that were completely unrelated to how safely the insured drove. Among these arbitrary rating factors were education level,

4 National Association of Insurance Commissioners, “2015/16 Auto Insurance Database Report,” 2018. https://www.naic.org/prod_serv/AUT-PB-15.pdf 5 United States Census Bureau 2017. https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=CF 6 California Senate Office of Research, “A Statistical Picture of Latinos in California 2017 Update,” July 2017. https://latinocaucus.legislature.ca.gov/sites/latinocaucus.legislature.ca.gov/files/forms/Statistical%20Pictu re%20of%20Latinos%20in%20California%20-%202017%20Update.pdf 7 Duke University, et al, “The Color of Wealth in Los Angeles,” March 2016. http://www.aasc.ucla.edu/besol/color_of_wealth_report.pdf

Insurance Commissioner Ricardo Lara February 21, 2019 Page 4 of 7 employment status, nature of job or business, and place of residence. (National Insurance Consumers Organization, Insurance In California: A 1986 Status Report For The Assembly, October 1986.)

In 1988, finding that “the existing laws inadequately protect consumers and allow insurance companies to charge excessive, unjustified and arbitrary rates,” California voters established a process by which the rating factors used by insurance companies to set auto insurance premiums are strictly regulated. Insurance Code section 1861.02(a) requires that premiums be determined principally by three specified rating factors – the insured’s driving safety record, annual mileage, and years of driving experience – and, to a lesser extent, by any optional rating factors that “the commissioner may adopt by regulation and that have a substantial relationship to the risk of loss.” (Ins. Code § 1861.02(a)(4) [emphasis added].) The current list of authorized optional rating factors can be found at 10 CCR 2632.5(d). (See Exh. H.) The use of any rating factor that has not been adopted by the Commissioner by regulation – that does not appear on that list – “shall constitute unfair discrimination,” which is a violation of Insurance Code section 1861.05(a).

In recent years, insurance companies have sought to evade these legal requirements by marketing what they call “affinity groups” to California residents, promising premium reductions to those who qualify. Examples of “affinity groups” include generic categories of occupations such as lawyers, doctors, engineers, business professionals, college graduates, homeowners, and other “groups” fabricated by insurance companies solely for the purpose of discriminating against motorists to whom the insurance companies do not want to sell insurance. (See Exh. I, which lists the occupation classifications used by Farmers, Allstate, Mercury, GEICO, AAA, Progressive and Liberty Mutual to rate drivers as disclosed in their automobile rate and class plan filings insurers are required to file pursuant to Proposition 103.)

However, no insurance company has presented any evidence that any education level, occupation or any other so-called “affinity group” bears any relationship to the risk of loss, much less the “substantial relationship” to the risk of loss required by the statute. Nor has the Commissioner ever adopted, by regulation, any “affinity group” classification as an optional automobile rating factor. Moreover, because “affinity groups” have not been subjected to the automobile rating factor rules set forth in the regulation, it is possible that these classifications have a greater weight and impact on premiums than the three factors that the voters mandated be the principal determinants of auto premiums – a result that violates Proposition 103.8

8 Insurance companies contend that “affinity groups” are authorized by Insurance Code section 1861.12. The argument is incorrect. Section 1861.12 was enacted to permit groups of consumers to independently join together to negotiate a “group plan” with a single insurance company. “Affinity groups,” by contrast, are marketing schemes concocted by insurance companies based on impermissible rating characteristics such as occupational and educational status. The suggestion that “affinity groups” are authorized by section 1861.12 cannot be squared with section 1861.02; such an interpretation would establish a loophole in Proposition 103 that would allow insurance companies to evade the voters’ explicit direction in section 1861.02 and the auto rating factor regulations that implement it. Obviously, the voters would not have enacted stringent regulation of automobile rating factors only to allow insurance companies to override section 1861.02 by creating an unregulated patchwork of “groups” that fit their preferred unfairly discriminatory rating categories.

Insurance Commissioner Ricardo Lara February 21, 2019 Page 5 of 7

Because the auto rating factor process established by Proposition 103 is a revenue- neutral, “zero-sum” system (see generally The Foundation for Taxpayer and Consumer Rights v. Garamendi (2005) 132 Cal. App. 4th 1352, 1367-1368), those who aren’t members of elite professions, people who have lost jobs or are otherwise unemployed, students, and retired people are paying higher premiums to subsidize those who do qualify. That is precisely the kind of arbitrary, unjust and discriminatory rating system that Proposition 103 was enacted by the voters to prevent.

A Regulation Is Urgently Needed to Protect the Public

The Department last held three informal workshops on “affinity groups” in 2014-2015, but unfortunately that inquiry never proceeded to a rulemaking hearing or adoption of any regulation. As a result, a growing number of Californians are being subjected to unlawful surcharges.

The public rulemaking process established by California law and expressly required by Proposition 103 is the most efficient method for addressing what has now become a nearly industry-wide abuse. Indeed, in an Allstate auto rate proceeding, the Administrative Law Judge agreed with the insurer and the Department that a rulemaking proceeding was preferable:

As suggested by Allstate and the Department, a rulemaking proceeding would be a desirable way of resolving some of the doubts about the affinity programs, since, given the Department’s consistent practice of approving them, a decision in this area could have far-reaching, industry-wide consequences. The many carriers using such programs, and the consumer organizations opposing or seeking to modify them, should have a full opportunity to be heard in formulating appropriate standards and clarifying regulations, and should not otherwise have the issues resolved in the context of reviewing a stipulated settlement of a single prior approval rate case.

(Proposed Decision, In the Matter of the Rate Application of Allstate Insurance Company, Allstate Indemnity Company, Northbrook Indemnity Company, File No. PA – 2013-00003, Nov. 14, 2013, pp. 24-25.)

Finally, a rulemaking will obviate the need for litigation to remedy the abuse. A proposed regulation is included below.

10 CCR 2632.4 Use of Rating Factors and Discounts is amended to add subdivision (c):

(c) No insurer shall use occupation, education level, or any surrogate for occupation or education level, or any generic classification pertaining to occupation or education, as a criterion for determining eligibility for an automobile insurance policy, or for determining automobile rates, premiums, discounts, or surcharges under Insurance Code sections 1861.02, 1861.05, or 1861.12 unless it has been adopted by the Commissioner as a rating factor as set forth in section 1861.02 (a)(4).

Insurance Commissioner Ricardo Lara February 21, 2019 Page 6 of 7

Authority for Petition and Rulemaking

The undersigned organizations submit this Petition pursuant to Government Code section 11340.6, which provides that “any interested person may petition a state agency requesting the adoption, amendment, or repeal of a regulation.”

As Insurance Commissioner, you have both the authority and the responsibility to enforce Proposition 103 and in particular, to take such actions as are necessary to protect California consumers and to obtain full compliance with California law. (Ins. Code § 12921(a).) The courts have recognized that the Commissioner has the necessary authority to implement and enforce the requirements of Proposition 103. (Calfarm Ins. Co. v. Deukmejian (1989) 48 Cal.3d 805, 824.)

Insurance Code section 1861.02(e) expressly vests the Commissioner with the responsibility and authority to promulgate regulations to enforce the law’s auto rating factor requirements.9

Immediate Moratorium on Further “Affinity Group” Programs

In connection with this request for a rulemaking, the undersigned organizations ask that you immediately order a moratorium on the processing of any applications that propose new automobile affinity group programs or changes to existing programs, effective until such time as a regulation is promulgated. Imposing a moratorium on further agency action is needed to protect California consumers as well as public confidence in the integrity of the agency you oversee.

Conclusion

As California’s elected Insurance Commissioner, you have the ability and responsibility to take immediate action to protect California’s communities against the use of unlawful, unauthorized and discriminatory rating factors. We look forward to your response to this Petition within thirty days, as required by Government Code section 11340.7, and to working with you to end this discriminatory practice in California.

Sincerely,

Harvey Rosenfield Consumer Watchdog

Amy Bach Guillermo Mayer United Policyholders Public Advocates Inc.

9 Your predecessors utilized this authority to promulgate an amendment to the auto rating factor regulations in circumstances identical to these. For example, in 2002, the Commissioner amended those regulations to bar insurance companies from applying the “persistency” optional rating factor in a manner that would allow an insurance company to consider an applicant’s prior insurance coverage – a rating factor expressly barred by Proposition 103. (See Cal. Code Regs., tit. 10, § 2632.5(d)(11).)

Insurance Commissioner Ricardo Lara February 21, 2019 Page 7 of 7

Matt Nelson Bruce Marks Presente.org Neighborhood Assistance Corporation of America

Raquel López Alexandra Soh La Casa de la Raza KIWA (Korean Immigrant Workers Alliance)

Eddie Kurtz Rosemary Shahan Courage Campaign Consumers for Auto Reliability and Safety

Doug Heller Ken McEldowney Consumer Federation of America Consumer Action

EXHIBIT A

Exhibit A: Farmers Quotes

Tester 1: Ann Doe, factory worker Tester 2: Barbara Doe, accountant Tester 3: Celia Doe, physician

All subjects reported identical home addresses, driving records, and vehicles. The level of coverage remains the same for each quote.

$126.93/month x 12 months = $1,523.16 per year

$110.88/month x 12 months = $1,330.56 per year

$110.88/month x 12 months = $1,330.56 per year

EXHIBIT B

Exhibit B: Progressive Quotes – Occupation

Tester 1: Deborah Doe, factory worker Tester 2: Evelyn Doe, attorney Tester 3: Gina Doe, physician

All subjects reported identical home addresses, driving records, and vehicles. The level of coverage remains the same for each quote.

$439/six months x 2 = $878 per year

$413/six months x 2 = $826 per year

$413/six months x 2 = $826 per year

EXHIBIT C

Exhibit C: GEICO Quotes

Tester 1: Helena Doe, Bachelor’s degree, factory worker Tester 2: Irene Doe, Bachelor’s degree, CEO/company president

All subjects reported identical home addresses, driving records, and vehicles. The level of coverage remains the same for each quote.

$488.28/six months x 2 = $976.56 per year

$425.88/six months x 2 = $851.76 per year

EXHIBIT D

Exhibit D: Progressive Quotes – Education

Tester 1: Jane Doe, high school diploma, office manager Tester 2: Kara Doe, Bachelor’s degree, office manager

All subjects reported identical home addresses, driving records, and vehicles. The level of coverage remains the same for each quote.

$439/six months x 2 = $878 per year

$413/six months x 2 = $826 per year

EXHIBIT E

Exhibit E: AAA Quotes

Tester 1: Lisa Doe, no affiliations Tester 2: Meredith Doe, alumni association member

All subjects reported identical home addresses, driving records, and vehicles. The level of coverage remains the same for each quote.

Total estimated premium = $1,017 per year

Total estimated premium = $941 per year

EXHIBIT F

Immediate Release: Contact: July 22, 2013 Peter Kitchen (202) 737-0766 Tom Feltner (202) 618-0310

MAJOR AUTO INSURERS CHARGE HIGHER RATES TO HIGH SCHOOL GRADUATES AND BLUE COLLAR WORKERS

National Consumer Survey Reveals That Large Majorities Reject the Use of Education and Occupation in Setting Auto Insurance Rates

Washington, DC – Today, the Consumer Federation of America (CFA) released a new analysis showing that some major auto insurers charge higher rates to drivers with less education and lower-status jobs. Among its findings, the research reveals that for the minimum liability coverage, which state governments require:  GEICO often charges a factory worker with a high school degree far higher annual premiums than a plant supervisor with a college degree – 45% more in Seattle ($870 vs. $599), 40% more in Hartford ($1299 vs. $926), 33% more in Oakland ($922 vs. $693), 23% more in Louisville ($2200 vs. $1791), 21% more in Chicago ($1013 vs. $840), and 20% more in Baltimore ($1971 vs. $1647).  At GEICO, these differences would be even greater if, for education, the comparisons also included no high school degree and a graduate degree. For example, the Baltimore factory worker would pay an annual premium of $2061 with no high school degree, an annual premium of $1971 with a high school degree, an annual premium of $1801 with a college degree, and an annual premium of $1722 with a graduate degree.  Progressive also often charges a factory worker with a high school degree higher annual premiums than a plant supervisor with a college degree – 33% more in Baltimore ($1818 vs. $1362), 14% more in Houston ($1406 vs. $1236), 9% more in Louisville ($2390 vs. $2185), 9% more in Denver ($995 vs. $911), and 8% more in Oakland ($736 vs. $684).  Liberty Mutual charges a high school graduate higher annual premiums than a college graduate – 13% more in Baltimore ($2116 vs. $1877), 13% more in Houston ($1373 vs. $1216), 12% more in Phoenix ($1592 vs. $1418), and 10% more in Hartford ($1913 vs. $1735). In five other cities studied – Atlanta, Louisville, Chicago, Denver, and Seattle – Liberty’s website quoted rates for a college graduate but not for a high school graduate.  In many cities, Farmers charges those who are neither professionals nor certain government workers five percent higher premiums. For each of these factors, all factors except education and income were held constant. These factors, including a perfect driving record, are described below.

“Auto insurers charge high premiums for minimal coverage to most working people, even those with perfect driving records, who live in urban areas,” said Stephen Brobeck, CFA’s Executive Director. “Since most Americans need a car and almost all states require the purchase of auto insurance, many lower-income workers are faced with the choice of paying these high, and often unaffordable prices, or breaking the law by driving without insurance,” he added. CFA estimates that one-quarter to one-third of drivers with household incomes under $36,000 – 40 percent of all households – are uninsured.

Public Rejects Use of Education and Income in Auto Insurance Rate-Making

Yet, a national survey has revealed that, by large majorities, the public rejects the use of education and occupation by auto insurers in setting rates. In a June 2012 survey of a representative sample of 1010 adult Americans, conducted by ORCI, 68% of respondents said it was unfair for auto insurers to use education, while 65% said it was unfair for insurers to use occupation, in setting rates. For those with moderate household incomes ($25,000-$50,000), the percentages were even higher – 74% for education and 69% for occupation. (Respondents were interviewed either by landline or cell phones, and the margin of error was plus or minus three percentage points.)

“The American public knows that it is unfair for auto insurers to use factors like education and occupation in setting rates,” said J. Robert Hunter, CFA’s Director of Insurance, a former Texas Insurance Commissioner, and a former Federal Insurance Administrator. “In effect, auto insurers are discriminating on the basis of income and race. States should prohibit the use of these demographic factors that bear no logical relation to insurer risk.”

Much research has shown that both education and occupation are highly correlated with income and ethnicity. While many states prohibit the use of education and occupation to deny coverage, they permit the use of these factors in setting rate levels. That helps explain why some quoted annual premiums for minimum liability coverage are so high – sometimes exceeding $3000, even $4000. These high rates, which few drivers if any pay, effectively deny low- and moderate-income consumers coverage.

Minimum Liability Rates Are High Across-the-Board for Moderate-Income Good Drivers in Urban Areas

The CFA analysis, conducted in May and June 2013, examined the use of education and occupation by the ten largest auto insurers by market share – State Farm, Allstate, GEICO, Progressive, Farmers, USAA, Liberty Mutual, Nationwide, Travelers, and American Family – in ten major urban areas in different parts of the country – Hartford, Baltimore, Atlanta, Louisville, Chicago, Houston, Denver, Phoenix, Oakland, and Seattle. CFA used the websites of these insurers to determine whether they use education and occupation in their pricing and, if so, the impact of the use of these factors. The driver studied was a 30-year old single woman renting in a moderate-income area (c. $30,000 median income), who was driving a 2003 Honda Civic, had driven for ten years with no accidents or moving violations, and was without insurance coverage for the past 15 days.

As the table below reveals, if this woman were a factory worker with a high school degree, she would be charged high to very high annual premiums for minimum liability coverage by the eight insurers whose websites permitted rate comparisons (USAA and American Family did not) in five representative cities. In more than three-quarters of the 40 cases (78%), annual premiums exceed $900 or were not quoted. And no premiums are lower than $500. By comparison, a special program for good, lower-income drivers in California – that is not subsidized either by taxpayers or by other drivers – charges annual premiums of no more than $338, even to drivers in high-risk urban areas.

“The quoted prices, especially the nine exceeding $2000, show that insurers either are overcharging lower-income consumers or are not interested in serving them,” said CFA’s Hunter. “Since state governments require purchase of auto insurance, state insurance commissioners have an obligation to address this issue. And the relatively new Federal Insurance Office should make the study of this problem a priority,” he added. Dodd-Frank legislation gave the FIO authority to “monitor the extent to which traditionally underserved communities and consumers, minorities, and low and moderate income persons have access to affordable insurance products.”

Table 1: Quoted Annual Premiums for a Typical Working Person With a Good Driving Record (see paragraphs above for her specific characteristics)

Hartford Baltimore Chicago Houston Oakland

State Farm $949 $1225 $624 $1034 $541 Allstate 3222 3008 1654 1366 608 GEICO 1299 1971 1013 783 922 Progressive 1498 1818 886 1406 736 Farmers 2540 2806 2860 1666 827 Liberty 1913 2116 NQ 1373 1231 Nationwide NQ 1320 826 696 952 Travelers 2364 4182 2000 1730 883

Differences Among Large Auto Insurers in Use of Education and Income in Rate-Making

Five of the ten largest auto insurers – GEICO, Progressive, Liberty Mutual, Farmers, and American Family -- apparently use education and occupation in their rate-making in most states.

GEICO uses education and occupation in its rate-making across the country. In many states, it gives equal weight to each. For example, in Hartford a factory worker would pay 28 percent more than a factory superintendent ($1299 vs. $1018), but a factory worker would pay 28 percent more with a high school degree than with a college degree (again $1299 vs. $1018). In Seattle, however, the GEICO website did not inquire about occupation but charged a factory worker with a high school degree 45 percent more than a factory worker with a college degree ($870 vs. $599). And in Atlanta the website did not inquire about either education or occupation.

Progressive tends to give somewhat greater weight to education than to occupation. For example, in Louisville it charged a factory worker only one percent more than a plant superintendent ($2390 vs. $2357), but charged a factory worker with a high school degree seven percent more than the factory worker with a college degree ($2390 vs. $2228). Like GEICO, in Seattle the website did not inquire about occupation but charged progressively less as educational level increased – an annual premium of $1134 for no high school degree, $1042 for a high school degree, $964 for a college degree, and $946 for a graduate degree. And like GEICO, in Atlanta the website did not inquire about either education or occupation.

As indicated earlier, Liberty’s quotes for a high school graduate were usually 10-13 percent higher than quotes for a college graduate. In one state, California, the insurer apparently also uses occupation as a rate-making factor. In Oakland, its quoted annual premium was $1074 for a factory workers and $892 for an executive.

Farmers’ quotes made distinctions between certain professionals and civil servants and “others.” In different cities, the “others” consistently were charged five percent higher rates.

American Family was difficult to research because its website required information about an actual, rather than a hypothetical, driver. However, it did ask for specific information about occupation, though it is not clear how the insurer factored that information into its rate-making.

State Farm, Allstate, USAA, Nationwide, and Travelers apparently do not use education or occupation in their rate-making, at least in the ten states studied.

“We commend auto insurers who are not using education and occupation in their rate- making,” said CFA’s Brobeck. “One reason insurance commissioners should address this issue is because these insurers may well feel pressured to adopt the discriminatory practices of GEICO and Progressive,” he added.

Allstate’s website did not ask for specific information about occupation but did require one to indicate whether one was employed or unemployed in many states, and in some states, to identify certain occupations such as firefighter or policeman, though it is not clear how Allstate used any of this information in rate-making.

Only in California did Travelers’ website ask for specific information about occupation, though it is not clear how the insurer uses this information in rate-making in that state.

CFA Continues Campaign for Fair, Affordable Rates for Low- and Moderate-Income Drivers Required to Purchase Auto Insurance in All States But New Hampshire

The Consumer Federation of America is a non-profit association of nearly 300 non-profit consumer groups that was established in 1968 to advance the consumer interest through research, education, and advocacy. In the past 18 months, CFA has released a series of reports showing that low- and moderate-income drivers in urban areas are charged high, and often unaffordable, auto insurance premiums for the minimum liability coverage required by all states except New Hampshire. These reports also reveal discriminatory practices that disadvantage drivers who are single, rent, lack continuous insurance coverage, live in moderate-income area, and in this latest analysis, have less education or work in low-paying, low-status occupations. These reports can be found on the CFA website, www.consumerfed.org.

To help make auto insurance more affordable to working people, CFA is working to curtail the use of discriminatory factors in rate-making and to create state programs, such as the one in California, that allows lower-income, good drivers to buy required liability coverage at reasonable rates.

EXHIBIT G

Exhibit G: Farmers Insurance Rate Filing Pages, October 2018

Page 1: Prior approval rate template, “Regular” program Page 2: Prior approval rate template, “Business and Professionals Group I” program State of California Company: Mid-Century Insurance Company and Farmers Insurance Exchange Department of Insurance (CDI) Line: Auto Liability and Physical Damage CDI File # (Department Use Only):

PRIOR APPROVAL RATE TEMPLATE FOR PROPERTY & LIABILITY LINES SUMMARY

Latest Year Adjusted Minimum Permitted Maximum Permitted Change at Minimum Change at Maximum Coverage/Form/Program Proposed % Annual Premium ($) Earned Premium ($) Earned Premium ($) % % Bodily Injury and Property Damage 823,131,775 610,193,128 889,127,490 -25.9% 8.0% 8.0% Uninsured Motorist 107,667,461 117,685,537 171,482,505 9.3% 59.3% 25.0% Medical Payment 20,284,250 16,013,686 23,333,938 -21.1% 15.0% 11.0% Collision 462,416,579 441,733,196 556,189,337 -4.5% 20.3% 1.3% Comprehensive 104,547,424 93,641,940 117,905,217 -10.4% 12.8% 6.4% Towing 12,949,374 9,838,817 12,388,123 -24.0% -4.3% -7.4%

Combined 1,530,996,862 1,289,106,303 1,770,426,609 -15.8% 15.6% 7.0%

Combined Total Earned Exposures for Latest Year: 1,264,400

Average Earned Premium $ per Exposure Latest Year Earned Coverage/Form/Program Latest Year Adjusted Minimum Permitted Maximum Permitted Proposed Exposures

Bodily Injury and Property Damage 651.01 482.60 703.20 703.20 1,264,400 Uninsured Motorist 89.44 97.76 142.45 111.80 1,203,770 Medical Payment 48.61 38.37 55.92 53.96 417,300 Collision 495.46 473.30 595.93 501.90 933,307 Comprehensive 114.53 102.58 129.16 121.86 912,859 Towing 23.19 17.62 22.18 21.48 558,483

Combined 1,210.85 1,019.54 1,400.21 1,295.39 1,264,400

Latest Year Projected Latest Year Projected Latest Year Adjusted Coverage/Form/Program Ultimate Loss & DCCE Ultimate Loss & DCCE Annual Premium ($) ($) Ratio Bodily Injury and Property Damage 823,131,775 489,388,690 59.5% Uninsured Motorist 107,667,461 93,910,783 87.2% Medical Payment 20,284,250 12,780,091 63.0% Collision 462,416,579 321,263,112 69.5% Comprehensive 104,547,424 67,770,329 64.8% Towing 12,949,374 7,120,803 55.0%

Combined 1,530,996,862 992,233,809 64.8%

05/08/2017 Edition Prior Approval Rate Template Page 2 State of California Company: Mid-Century Insurance Company and Farmers Insurance Exchange Department of Insurance (CDI) Line: Auto Liability and Physical Damage CDI File # (Department Use Only):

PRIOR APPROVAL RATE TEMPLATE FOR PROPERTY & LIABILITY LINES SUMMARY

Latest Year Adjusted Minimum Permitted Maximum Permitted Change at Minimum Change at Maximum Coverage/Form/Program Proposed % Annual Premium ($) Earned Premium ($) Earned Premium ($) % % Bodily Injury and Property Damage 250,051,187 210,527,164 306,758,299 -15.8% 22.7% 6.1% Uninsured Motorist 32,727,852 32,672,244 47,606,598 -0.2% 45.5% 45.5% Medical Payment 7,209,423 5,738,061 8,360,907 -20.4% 16.0% -0.6% Collision 180,449,419 175,933,336 221,516,234 -2.5% 22.8% 2.2% Comprehensive 34,374,936 29,782,462 37,498,855 -13.4% 9.1% 5.5% Towing 3,977,584 2,709,796 3,411,882 -31.9% -14.2% -7.4%

Combined 508,790,400 457,363,063 625,152,775 -10.1% 22.9% 7.0%

Combined Total Earned Exposures for Latest Year: 431,104

Average Earned Premium $ per Exposure Latest Year Earned Coverage/Form/Program Latest Year Adjusted Minimum Permitted Maximum Permitted Proposed Exposures

Bodily Injury and Property Damage 580.03 488.34 711.56 615.14 431,104 Uninsured Motorist 77.66 77.18 112.46 112.97 421,404 Medical Payment 49.72 39.57 57.65 49.40 145,007 Collision 562.26 548.19 690.22 574.63 320,936 Comprehensive 94.68 82.03 103.29 99.88 363,061 Towing 21.01 14.31 18.02 19.46 189,315

Combined 1,180.20 1,060.91 1,450.12 1,262.64 431,104

Latest Year Projected Latest Year Projected Latest Year Adjusted Coverage/Form/Program Ultimate Loss & DCCE Ultimate Loss & DCCE Annual Premium ($) ($) Ratio Bodily Injury and Property Damage 250,051,187 168,751,448 67.5% Uninsured Motorist 32,727,852 26,684,075 81.5% Medical Payment 7,209,423 4,494,462 62.3% Collision 180,449,419 127,917,423 70.9% Comprehensive 34,374,936 21,555,771 62.7% Towing 3,977,584 1,961,364 49.3%

Combined 508,790,400 351,364,544 69.1%

05/08/2017 Edition Prior Approval Rate Template Page 2

EXHIBIT H

§ 2632.5. Rating Factors., 10 CA ADC § 2632.5

(H) In no event shall an insurer require a policyholder to provide information from a prior insurer to confirm mileage estimated or driven.

(I) Nothing in this section shall be construed to affect the ability of an insurer to decline to issue, cancel, or nonrenew a policy in accordance with any other applicable provision of California law.

(3) “Third Mandatory Factor” as used in Subchapter 4.7, is the number of years of driving experience the insured has, per California Insurance Code Section 1861.02(a)(3). This factor means number of years of experience that the driver rated on the insured vehicle has been licensed to drive in any jurisdiction. To the extent that a policy provides coverage for motorcycles or motor-driven cycles, as defined in California Vehicle Code Sections 400 and 405, this factor shall refer to the number of years that the driver rated on the insured vehicle has been licensed to drive such vehicles in any jurisdiction.

(d) In addition to the rating factors set forth in subdivision (c), an insurer's class plan, and all rates and premiums determined in accordance therewith, may utilize the following optional rating factors (the “Optional Factors”):

(1) Type of vehicle;

(2) Vehicle performance capabilities, including alterations made subsequent to original manufacture;

(3) Type of use of vehicle (pleasure only, commute, business, farm, commute mileage, etc.);

(4) Percentage use of the vehicle by the rated driver;

(5) Multi-vehicle households;

(6) Academic standing of the rated driver;

(7) Completion of driver training or defensive driving courses by the rated driver;

(8) Vehicle characteristics, including engine size, safety and protective devices, damageability, repairability, and theft deterrent devices;

(9) Marital status of the rated driver;

(10) Persistency:

© 2019 Thomson Reuters. No claim to original U.S. Government Works. 6 § 2632.5. Rating Factors., 10 CA ADC § 2632.5

(A) At policy renewal, persistency credit may be applied by an insurer or affiliate for the current named insured. Persistency credit may also be applied when issuing a separate new automobile policy for a person who is not the named insured on a policy, but is otherwise currently insured.

(B) An insurer shall not apply a persistency credit for a new policy issued to an individual, unless that individual is currently insured. Nor shall any insurer apply persistency, at any time, when based in whole or in part upon automobile insurance coverage provided by a non-affiliated insurer.

(C) This subsection shall not be construed to expand or restrict an insurer's ability to obtain evidence of a person's driving safety record. However, when such evidence concerns proof of prior insurance, this subsection shall apply.

(D) For purposes of this subsection, “currently insured” means a person who is presently covered for automobile insurance by the insurer or affiliate, other than as an unnamed person who is covered under a permissive user or similar provision.

(E) As used in this subsection, “affiliate” has the same meaning as defined in California Insurance Code section 1215.

(11) Non-smoker;

(12) Secondary Driver Characteristics. For drivers not assigned as a primary or secondary driver to another vehicle, this factor may be composed of a combination of the following factors: Safety Record, Years Licensed, Martial Status, Driver Training, and Academic Status;

(13) Multi-policies with the same, or an affiliated, company;

(14) Relative claims frequency. This factor shall contain a maximum of twenty categories and shall reflect where the insured vehicle is garaged. These categories shall be based on grouping the zip codes in the state into bands. Alternately, the bands could be based on grouping the census tracts in the state. Each band shall contain areas with a similar average claims frequency. In the event that the data for a zip code or census tract is not fully credible, the adjustment process described in Section 2632.9(d) shall be followed;

(15) Relative claims severity. This factor shall contain a maximum of twenty categories and shall reflect where the insured vehicle is garaged. These categories shall be based on grouping the zip codes in the state into bands. Alternately, the bands could be based on grouping the census tracts in the state. Each band shall contain areas with a similar average claims severity. In the event that the data for a zip code or census tract is not fully credible, the adjustment process described in Section 2632.9(d) shall be followed.

(e) Except as expressly provided in this subsection and in section 2632.5(c)(2)(F)(viii) the three mandatory factors may not be combined with any other factor. Optional rating factors for Percent Use, Academic Standing, Marital Status, and Driver Training may be combined with number of years of driving experience. If an insurer elects to combine number of years of driving experience with Percent Use, Academic Standing, Marital Status, or Driver Training, the insurer shall

© 2019 Thomson Reuters. No claim to original U.S. Government Works. 7

EXHIBIT I

GOVERNMENT EMPLOYEES INSURANCE COMPANY

PROFESSIONAL GROUP INSURANCE PLAN – CALIFORNIA

*Rating Rules

For those risks meeting the group eligibility below, premiums will be reduced by the following percentages:

Bodily Injury 11% Property Damage 11% Collision 22% Comprehensive 40% Uninsured Motorists – BI 30% Uninsured Motorists – PD 30% Medical Payments 30% Rental Reimbursement 23% Emergency Road Service 23% MBI 27%

This reduction will not apply if the named insured/applicant or spouse or registered domestic partner of the named insured is already receiving a lower rate under another Group Insurance Plan. This reduction will not apply to motor homes or travel trailers covered under Miscellaneous Rule 6.

Group Eligibility

The named insured/applicant or spouse or registered domestic partner of the named insured must be an operator and a professional Federal government employee in an administrative or technical position, employed in one of the following Professional Groups or retired from one of the following Professional Groups and no longer employed. These Professional Groups may require at least a Bachelor’s degree, license, or a professional certification/designation.

1 EFFECTIVE 04/01/2018 GOVERNMENT EMPLOYEES INSURANCE COMPANY

PROFESSIONAL GROUP INSURANCE PLAN – CALIFORNIA

Accountant - has an Accounting degree and is employed as an Accountant. Actuary Account Executive Administrator Advisor Air Traffic Controller Airport Manager Ambassador Analyst Anesthesiologist Architect - has a degree in Architecture and is employed as an Architect. Art Appraiser Assistant Airport Manager Assistant City Manager Assistant Operations Manager Assistant Personnel Manager Assistant Principal Assistant Productions Manager Assistant Range Manager Audiologist Bank Examiner Bank Manager Bank Officer Bank Owner Berkshire Hathaway Employees –must be employed by or retired from Berkshire Hathaway or any of its 80% or more owned subsidiaries. Broadcaster Cartographer Child Counselor City Manager Claims Examiner Coach Commercial Artist Comptroller Computer Programmer Computer Systems Engineer Conservationist Construction Inspector Consultant Controller (Financial) Co-op Agent Copywriter Coroner Curator Dentist – has a Medical degree Dietitian Economist Editor Educational Counselor Educator - is credentialed as a teacher or educational administrator by the State of California Commissions on Teacher Credentialing and holds a "Clear", Professional Clear", "Life" or "Preliminary" designation or is employed full-time as a college or university teacher or professor. Employee Benefits Supervisor

2 EFFECTIVE 10/01/2013 GOVERNMENT EMPLOYEES INSURANCE COMPANY

PROFESSIONAL GROUP INSURANCE PLAN – CALIFORNIA

Employment Agent Engineer/Draftsman/Technical Designer - has a Bachelor’s degree in Engineering and/or is licensed and employed as an Engineer/Draftsman/Technical Designer. Epidemiologist: Non-Physician Executive/Director Export Agent Extension Service Agent Field Underwriter Financial Analyst/Auditor Flight Instructor Food Technician Forester Fundraiser *General Manager Geographer Graphic Designer High Tech Salesman Historian Human Resources Manager Import/Export Agent Industrial Hygienist Inspector - White Collar Instructor Insurance Broker Insurance Underwriter Interpreter Investment Broker Journalist Judge - has a law degree and is an appointed or elected Judge. Lawyer - has a law degree and is employed as a Lawyer. Librarian - has a degree in Library Science and is employed as a Librarian. Lobbyist Manufacturer's Representative - High Tech Mathematician Mental Health Counselor Merchant Marine Officer Mining Engineer Mortgage Broker Mortician Museum Archivist Navigator - is a licensed navigator and is employed as a Navigator. Nutritionist. Operations Manager Optometrist Penologist Personnel Management Specialist Personnel Recruiter Pharmacist - has a Bachelor’s degree in pharmacology and is a licensed and practicing Pharmacist. Physical Therapist, APTA certified Physician – has a medical degree. Pilot - is a licensed pilot holding at least an airline transport pilot certification and is employed as a Pilot.

3 EFFECTIVE 01/05/2017 GOVERNMENT EMPLOYEES INSURANCE COMPANY

PROFESSIONAL GROUP INSURANCE PLAN – CALIFORNIA

Planner Police Captain Police Chief Position Classifier Postmaster Principal Printer Planner Production Controller Production Manager Production Planner Professional Staff Manager Project Manager Psychologist Public Relations Publisher Purchasing Agent/Buyer Purser-Ship Radiologist Range Ecologist Real Estate Appraiser Real Estate Broker Registrar Reporter Researcher Safety Engineer Sanitarian Scientist - has at least a Masters degree in their discipline and is employed as a Scientist. Secretary Ship Captain Ship Master Ship Officer Speech Pathologist Staffing Specialist State Examiner Stock & Bonds Broker Surveyor (licensed) Tax Examiner Technical Staff Manager Telecomm Officer Therapist Toxicologist Training Specialist Translator Treasurer Treasury Agent Tutor Veterinarian Warden Wastewater Treatment Plant Operator White Collar Contractor/Developer/Inspector Writer – Commercial

4 EFFECTIVE 10/01/2013 MERCURY INSURANCE COMPANY

E. MULTI POLICY DISCOUNT

A Multi Policy Discount is available for insureds that have a Homeowner, Condominium or Tenants policy with the Company. To qualify the Agent must provide the HO or PK policy number with the request for the discount.

F. GROUP DISCOUNTS – Documentation supporting these discounts must accompany the application. All vehicles on the policy (except trailers) including 07(X) vehicles will qualify. If submitted at a later date, the discount will be effective when received by the Company or Agent. 1. Scientists and Engineers A reduction in the BI, PD, UMBI, Medical, Comprehensive and Collision premiums is available if an insured is a member of one of the professional groups listed. Engineer - The driver must have a Bachelor’s degree (or higher degree) or be licensed as an engineer in one of the following fields of engineering or any other engineering field: Aeronautical Chemical Mechanical Aerospace Civil Nuclear Architectural Electrical Petroleum Gas Structural

Scientist - The driver must have a Bachelor’s degree (or higher degree) in one of the following physical sciences:

Astronomy Cybernetics Mathematics Biochemistry Geology Meteorology Biology Geophysics Physics Chemistry Information Systems Planetary Systems Computer Science 2. Educators A reduction in the BIPD, UMBI, Medical, Comprehensive and Collision premiums is available if an insured is credentialed as a teacher or educational administrator and holds a “Clear”, “Professional Clear”, “Life”, “Preliminary”, “Temporary” or “Emergency” designation or is employed full-time as a teacher or professor. 3. California Medical Association A reduction in BIPD, UMBI, Medical, Comprehensive and Collision premiums is available if an insured is a member of the California Medical Association. 4. Mercury Insurance Employees A reduction in BIPD, UMBI, Medical, Comprehensive and Collision premiums is available if an insured is an employee of Mercury Insurance Services, LLC, and Affiliated Companies.

5. Los Angeles County Bar Association

A reduction in BIPD, UMBI, Medical, Comprehensive and Collision premiums is available if an insured is a member of the Los Angeles County Bar Association. The discount shall be increased if the Named Insured is willing to sign an Arbitration Agreement (U-241) with Mercury. Use Group 2004 for those eligible for the increased discount.

6. Cal CPA A reduction in BIPD, UMBI, Medical, Comprehensive, and Collision premiums is available if an insured is a member of the California Society of Certified Public Accountants. Note, Group 2007 will be assigned if this discount is added mid-term or at renewal.

17 2/18/2017

MERCURY INSURANCE COMPANY

7. Alumni Association A reduction in BIPD, UMBI, Medical, Comprehensive, and Collision premiums is available if an insured is a member of a recognized alumni association of a 4 year accredited college.

G. ANTI-THEFT DISCOUNTS – Documentation supporting the discount for a Lo Jack, Tele Trac or similar type device must accompany the application.

H. PERSISTENCY DISCOUNT

A discount will be applied to policy renewals or rewrites. To qualify, the insured must have had coverage with Mercury for at least one year with no lapse in coverage greater than 30 days. This discount applies only to BI, PD, UMBI, MP, Comprehensive, and Collision coverages.

I. REALDRIVE

A reduction in BIPD, UMBI, Medical, Comprehensive, and Collision premiums is available for insureds that consent to participate in the RealDrive program. The program is offered at a Policy Level and the rating is applied at the Vehicle Level. All eligible vehicles must participate in the program in order to qualify and continue in the program. The RealDrive program premium adjustment is based on one of the following factors:

1. RealDrive Enrollment Factor o The RealDrive Enrollment Factor will be applicable until the actual calculated annual mileage can be determined.

2. RealDrive Factor o The RealDrive Factor shall be based on the calculated annual mileage factor from the rate manual.

Historical odometer readings will be used to determine the verified annual mileage used to rate the vehicles on the policy. All vehicles will be subject to attempts to collect the necessary odometer readings to calculate the verified mileage. Odometer readings will be collected at New Business and at least every other Renewal. Verification may be required for odometer readings supplied by the insured or an agent of the insured.

Sources for Odometer Readings:

The following are potential sources of odometer reading(s) that the Company may consider in the calculation of verified mileage. The Company may use one source exclusively or a combination of sources:

 Odometer readings of the insured Vehicle or Vehicles, made by an employee of the insurer, an agent of the insurer; or a third-party vendor retained by the insurer  Odometer readings recorded by an automotive repair dealer in the ordinary course of the business of servicing a vehicle, provided to the insurer by the policyholder or by a vendor retained by the insurer  Odometer readings obtained from smog check stations licensed by the California Bureau of Automotive Repair, from the California Department of Motor Vehicles, or any other governmental agency that maintains public records of vehicle odometer readings, provided to the insurer by the policyholder or by a vendor retained by the insurer  Self-reported odometer readings provided with acceptable documentation  A technological device

18 2/18/2017

Rating Manual Rating Table 36

INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB PROPOSED RATES - CALIFORNIA

GROUP PROGRAM MULTIPLIERS

BI PD MP CP CL UC RR UM

Scientist, Educators, Engineers 0.921 0.921 0.921 0.921 0.921 0.921 0.921 0.921 Medical Professionals, CPAs, and Alumni Associations

Lawyers 0.985 0.985 0.985 0.985 0.985 0.985 0.985 0.985

Select Groups 0.925 0.925 0.925 0.925 0.925 0.925 0.925 0.925

Non-Qualifying Policyholders 1.000 1.000 1.000 1.000 1.000 1.000 1.000 1.000

A description of the qualification criteria may be found in the Manual Rules. CALIFORNIA PRIVATE PASSENGER AUTO INSURANCE MANUAL RULES

RULE 43 – ALLSTATE® AUTO PROGRAMS

Separate base rates are used to determine the applicable premium where the policyholder or spouse is a member of at least one of the following program groups:

A. Specialized Professionals B. Professionals C. Homeowner Association D. Condo Association E. Alumni Association F. Allstate Motor Club®

1. General Requirements

i. All vehicles insured under the policy and all Private Passenger Automobile policies held by the named insured are eligible for the group.

ii. If a policyholder or spouse is a member of more than one group, the policy will be placed into the group in which the policy would receive the lowest rate.

Note: A registered domestic partner may also be considered as a spouse for the purposes of this rule.

iii. Only one group may be applied to a policy.

iv. In the event that the qualifying insured is removed as a rated operator on the policy, the vehicles on the policy will no longer be eligible to receive the base rates for that specific group.

v. The group base rates will not apply prior to Allstate verifying program eligibility. Verification of Eligibility may require documentation support provided by the customer.

vi. Policies which are not eligible for Groups A through F will receive the base rates applicable for the Standard Program. These base rates are listed on Rate Page R- 9G.

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CALIFORNIA PRIVATE PASSENGER AUTO INSURANCE MANUAL RULES

2. Group Definitions

A. Specialized Professionals Group Eligibility:

When the named insured or spouse is a member of one of the following occupational groups as defined in the Allstate Insurance Company, Allstate Indemnity Company, and Allstate Northbrook Indemnity Company Underwriting Guidelines, all vehicles insured under the policy held by the named insured qualify for the Specialized Professionals program group.

i) The named insured/applicant or spouse is a degreed professional in the one of the following occupational groups: Education or Library Science, Science, Engineering, or Information Technology.

ii) Proof of occupation may be required, such as a degree from a four-year accredited college/university, or a professional certification, designation, or license

B. Professionals Group Eligibility:

When the named insured or spouse is a member of one of the following occupational groups as defined in the Allstate Insurance Company, Allstate Indemnity Company, and Allstate Northbrook Indemnity Company, all vehicles insured under the policy held by the named insured qualify for the Professionals program group.

i) The named insured/applicant or spouse is a degreed professional in the of the following occupational groups: Business Management, Marketing, Financial Services, Health Care, Law, Government, Military, or Social Services.

ii) Proof of occupation may be required, such as a degree from a four-year accredited college/university, or a professional certification, designation, or License.

4-1-2015 ALLSTATE INSURANCE COMPANY Page 43-2 CALIFORNIA PRIVATE PASSENGER AUTO INSURANCE MANUAL RULES

C. Homeowner Association Group Eligibility:

Definitions:

Active: Assessed with a fee on a specified timeline, established by the association.

When the named insured or spouse is a member of an active Homeowner Association, all vehicles insured under the policy held by the named insured qualify for the Homeowner-Association program group.

D. Condo Association Group Eligibility:

Definitions:

Active: Assessed with a fee on a specified timeline, established by the association.

When the named insured or spouse is a member of an active Condo Association, all vehicles insured under the policy held by the named insured qualify for the Condo-Association program group.

E. Alumni Association Group Eligibility:

When the named insured or spouse is a member of a recognized alumni association of a four-year accredited college/university, all vehicles insured under the policy held by the named insured qualify for the Alumni Association program group.

F. Allstate Motor Club® Group Eligibility:

When the named insured or spouse is a member of the Allstate Motor Club®, all vehicles insured under the policy held by the named insured qualify for the Allstate Motor Club® program group.

G. Standard Program Eligibility:

When the named insured or spouse is ineligible or does not qualify for Program Groups as described in 2.A. through 2.F., all vehicles insured under the policy held by the named insured qualify for the Standard program.

8-1-2013 ALLSTATE INSURANCE COMPANY Page 43-3 State of California Farmers Insurance Exchange, Mid-Century Insurance Company & Truck Insurance Exchange Private Passenger Automobile Rules

BUSINESS AND PROFESSIONAL GROUPS

Eligibility

All named insureds in the household that have a related relationship (other than ‘O’ for other and ‘U’ for unknown) will be given the highest qualifying discount. Drivers coded as non- drivers (i.e. ‘OH’ for Out-of Household) will not qualify any policy in the household for the discount. All named insureds that are not related will qualify for their own discount. When situations exist with more than one named insured on a policy and there is at least one unrelated named insured on a policy, the highest qualifying discount will be given (which could either be the highest related or highest unrelated).

Group I Group II Certified Public Accountants (CPA’s) Architects Dentists FIG Federal Credit Union Educators Firefighters Engineers Lawyers/Judges Physicians/Surgeons Registered Nurses Scientists Police Offices/Law Enforcement Officers Veterinarians Aviation Professionals Physical and Occupational Therapists Speech Audiologists and Pathologists Librarians Real Estate Agents and Brokers

Small Business Policyholders (Owners & Officers) Workers’ Compensation Policyholders (Owners & Officers) Zurich Employees/Agents

Qualification

Personal auto policy does not include the following: Antique, Campers, Dune Buggies, Farm Trailers, Farm Equipment/Machinery, Motor home Plus, Motorcycles, and Premium Determination (both Normal and Restricted Use).

Only one Business and Professional Group discount can be applied to each policy.

Foreign Degrees and transcripts are acceptable for membership verification but they must be accompanied by a certified translation of the document.

Retirees

Retirees previously employed in a listed Group I or Group II occupation are eligible with supporting documentation: a retirement letter from the former employee, or a pay stub from a pension plan. The retirement letter must be written by the former employer’s human resources representative. It must be clearly legible, provided on a company letterhead, showing the name, mailing address and phone number of the writer. The pay stub from a pension plan must be less than 90 days old, and have the former employee’s legible name and address.

New Business & Renewal Effective 12-31-2018 28

Progressive Select Insurance Company PP Auto Liability and Physical Damage

Business and Professional Group Program Guidelines

This group program will use the current "master" Class Plans approved for Progressive Select Insurance Company and United Financial Casualty Company, and will only deviate from the regular program in base rate. All underwriting rules and factors will be the same.

To qualify for a Business and Professional Group, the named insured/applicant or spouse is a member of one of the defined occupational groups. Group rates will be adjusted from the rates reflected in the United Financial Casualty or Progressive Select Automobile manual as set forth in the base rate table of the group rate filings. Any policy will only be placed in one group.

Group 1 – Business Management/Marketing – Named insured/applicant or spouse is a degreed professional in the field of business management or marketing. Qualifying occupations include accountant, auditor, analyst, bookkeeper, consultant, human resource specialist, general manager/executive, marketing specialist, and public relations specialist. Proof of occupation may be required, such as a college degree.

Group 2 – Educator/Library Science – Named insured/applicant or spouse is a degreed professional in the field of education or library science. Qualifying occupations include college professor, counselor, librarian, curator, principal, administrator, and teacher. Proof of occupation may be required, such as a college degree.

Group 3 – Financial Services - Named insured/applicant or spouse is a degreed professional in the field of financial services. Qualifying occupations include accountant, agent, broker, analyst, appraiser, claims adjuster, claims investigator, financial advisor, financial investor, loan officer, property manager, supervisor, underwriter, actuary, and manager. Proof of occupation may be required, such as a college degree.

Group 4 – Health Care - Named insured/applicant or spouse is a degreed professional in the field of health care. Qualifying occupations include chiropractor, podiatrist, dentist, orthodontist, doctor, surgeon, pharmacist, registered nurse, veterinarian, health care supervisor, manager, and administrator. Proof of occupation may be required, such as a college degree.

Group 5 – Science/Engineering/Information Technology - Named insured/applicant or spouse is a degreed professional in the field of science, engineering, or information technology. Qualifying occupations include administrator, analyst, architect, drafter, computer programmer, engineer, scientist, researcher, engineering or IT supervisor, and manager. Proof of occupation may be required, such as a college degree.

Group 6 – Law/Government/Military - Named insured/applicant or spouse is a degreed professional in the field of law, government, or military. Qualifying occupations include auditor, analyst, examiner, lawyer, judge, mediator, legal support staff, military officer, military warrant officer, legal or government supervisor, and manager. Proof of occupation may be required, such as a college degree.

Group 7 – Social Services - Named insured/applicant or spouse is a degreed professional in the field of social services. Qualifying occupations include clergy, program director, counselor, psychologist, therapist, social service worker, social service supervisor, and manager. Proof of occupation may be required, such as a college degree. LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

SURCHARGE AND DISCOUNT APPLYING TO ALL COVERAGES WHICH PERMIT SURCHARGES AND DISCOUNTS

25. Group Savings Plus Discount For employees of a qualifying participating employer, members of a qualifying participating association and partnership, the rates otherwise applicable may be reduced by 5% (Rating factor 0.95). This reduction applies to all vehicles rated in accordance with the Automobile Rating Manual. The following clients are marketed under unique names in our Group Savings Plus program:

Client Program Name CUNA TruStage Auto and Home Insurance American Psychological Association & United Parcel Service Liberty for All Comerica Bank Comerica Insurance Advantage Florida Education Association Educators Plus Aon Corporation Voluntary Personal Protection Program Navy Federal Credit Union Navy Federal Homeowners Insurance Program Audi of America Audi Prestige Insurance BJ's Wholesale Club BJ's Member Value Program BMW of North America BMW Performance Insurance MINI of North America MINI Motoring Insurance smart Insurance foryou program Subaru of America Subaru Advantage Insurance Volkswagen of America MyVWInsurance Mercedes-Benz First Class Insurance Hyundai Hyundai Power Protect Program Kia Power Protect Program AAA Central West NJ AAA Insurance Advantage

CALIFORNIA SECTION D PAGE 01a MAY 2013 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

26. Educators/Corporate & Technical Professionals Group Any named insured that is a member of one of the professional groups listed below, will be eligible to have their applicable rates reduced by 5% (Rate Factor .95) for all motor vehicle policies held by the named insured.

If the insured qualifies for any combination of Group Saving Plus discount, Educators/Corporate & Technical Professionals discount, and/or Sponsored Alumni Group discount, the maximum individual discount amount will be applied. When an insured becomes eligible for the Persistency Discount, they will move into the Basic rating program if it offers a lower rate.

Account Manager Biological Technician Accountant And Auditor Biomedical Engineer Actuary Bookkeeper Administrative Law Judge, Adjudicator, Or Hearing Officer Bookkeeping, Accounting, Or Auditing Clerk Advertising Or Promotions Manager Broadcast News Analyst Advertising Sales Agent Broadcast Technician Aerospace Engineer Brokerage Clerk Agricultural Engineer Budget Analyst Agricultural Sciences Teacher, Postsecondary Business Operations Specialist, All Other Airline Pilot, Copilot, Or Flight Engineer Business Teacher, Postsecondary Analyst Captain, Mate, Or Pilot Of Water Vessel Anesthesiologist Cartographer Or Photogrammetrist Animal Scientist Chemical Engineer Anthropologist Or Archeologist Chemist Anthropology Or Archeology Teacher, Postsecondary Chemistry Teacher, Postsecondary Appraisers Or Assessors Of Real Estate Chief Executive Arbitrator, Mediator, Or Conciliator Child, Family, Or School Social Worker Architect, Except Landscape And Naval Chiropractor Architecture Teacher, Postsecondary Civil Engineer Archivist Claims Adjuster, Examiner, Or Investigator Area, Ethnic, Or Cultural Studies Teacher, Postsecondary Clinical, Counseling, Or School Psychologist Art Director Commercial Or Industrial Designer Art, Drama, Or Music Teacher, Postsecondary Commercial Pilot Astronomer Communications Teacher, Postsecondary Atmospheric Or Space Scientist Compensation And Benefits Manager Atmospheric, Earth, Marine, And Space Sciences Teacher, Postsecondary Compensation, Benefits, And Job Analysis Specialist Audiologist Computer And Information Scientist, Research Audio-Visual Collections Specialist Computer Hardware Engineer Biochemist Or Biophysicist Computer Or Information Systems Manager Biological Science Teacher, Postsecondary Computer Programmer Biological Scientist, All Other Computer Science Teacher, Postsecondary

CALIFORNIA SECTION D PAGE 01b September 2018

LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Computer Software Engineer, Applications Environmental Science Teacher, Postsecondary Computer Software Engineer, Systems Software Environmental Scientist Or Specialist, Including Health Computer Specialist, All Other Epidemiologist Computer Systems Analyst Executive Secretary Or Administrative Assistant Conservation Scientist Family Or General Practitioner Construction Or Building Inspector Financial Analyst Consultant Financial Examiner Credit Analyst Financial Manager Credit Authorizer, Checker, Or Clerk Financial Specialist, All Other Criminal Justice Or Law Enforcement Teacher, Postsecondary Fire Inspector Or Investigator Criminalist Food Scientist Or Technologist Curator Foreign Language Or Literature Teacher, Postsecondary Database Administrator Forestry Or Conservation Science Teacher, Postsecondary Dentist, All Other Specialist Funeral Director Dentist, General General Or Operations Manager Dietitian Or Nutritionist Geographer Drafter, All Other Geography Teacher, Postsecondary Economics Teacher, Postsecondary Geoscientist, Except Hydrologist Or Geographer Economist Graduate Teaching Assistant Editor Graphic Designer Health And Safety Engineer, Except Mining Safety Engineers And Education Administrator, All Other Inspectors Education Administrator, Elementary And Secondary School Health Specialties Teacher, Postsecondary Education Administrator, Postsecondary Historian Education Administrator, Preschool And Child Care Center/Program History Teacher, Postsecondary Education Teacher, Postsecondary Home Economics Teacher, Postsecondary Educational, Vocational, Or School Counselor Human Resources Manager, All Other Human Resources, Training, And Labor Relations Specialist, All Electrical And Electronics Drafter Other Electrical Engineer Hydrologist Electronics Engineer, Except Computer Industrial Engineer Elementary School Teacher, Except Special Education Industrial-Organizational Psychologist Engineer, All Other Instructional Coordinator Engineering Manager Insurance Broker Engineering Teacher, Postsecondary Insurance Sales Agent English Language Or Literature Teacher, Postsecondary Insurance Underwriter Environmental Engineer Internist, General

CALIFORNIA SECTION D PAGE 02 APRIL 2012 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Interpreter Or Translator Middle School Teacher, Except Special And Vocational Education Judge, Magistrate Judge, Or Magistrate Mining Or Geological Engineer, Including Mining Safety Engineer Kindergarten Teacher, Except Special Education Multi-Media Artist Or Animator Landscape Architect Museum Technician Or Conservator Law Clerk Network And Computer Systems Administrator Law Teacher, Postsecondary Network Systems And Data Communications Analyst Lawyer Nuclear Engineer Legislator Nursing Instructor Or Teacher, Postsecondary Librarian Obstetrician Or Gynecologist Library Science Teacher, Postsecondary Occupational Therapist Library Technician Operations Research Analyst Life Scientist, All Other Optometrist Logistician Oral Or Maxillofacial Surgeon Management Analyst Orthodontist Manager, All Other Orthotist Or Prosthetist Marine Engineer Or Naval Architect Pediatrician, General Market Research Analyst Personal Financial Advisor Marketing Manager Pharmacist Marriage Or Family Therapist Philosophy Or Religion Teacher, Postsecondary Materials Engineer Phlebotomist Materials Scientist Physical Scientist, All Other Mathematical Science Occupation, All Other Physical Therapist Mathematical Science Teacher, Postsecondary Physician Assistant Mathematical Technician Physician Or Surgeon, All Other Mathematician Physicist Mechanical Drafter Physics Teacher, Postsecondary Mechanical Engineer Podiatrist Mechanical Engineering Technician Political Science Teacher, Postsecondary Medical Or Health Services Manager Political Scientist Medical Or Public Health Social Worker Postmaster Or Mail Superintendent Medical Records Or Health Information Technician Postsecondary Teacher, All Other Medical Scientist, Except Epidemiologist Preschool Teacher, Except Special Education Mental Health Counselor Project Manager Mental Health Or Substance Abuse Social Worker Prosthodontist Microbiologist Psychiatrist

CALIFORNIA SECTION D PAGE 03 APRIL 2012 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Psychologist, All Other Software Engineer Psychology Teacher, Postsecondary Soil Or Plant Scientist Public Relations Manager Special Education Teacher, Middle School Special Education Teacher, Preschool, Kindergarten, And Public Relations Specialist Elementary School Purchasing Agent Or Buyer, Farm Products Special Education Teacher, Secondary School Purchasing Agent, Except Wholesale, Retail, And Farm Products Speech-Language Pathologist Purchasing Manager Statistical Assistant Radiation Therapist Statistician Real Estate Broker Substance Abuse Or Behavioral Disorder Counselor Recreation Or Fitness Studies Teacher, Postsecondary Surgeon Reporter Or Correspondent Surveyor Research Scientist Tax Examiner, Collector, Or Revenue Agent Retail Business Owner Tax Preparer Retail Sales Director Teacher Or Instructor, All Other Sales Engineer Technical Writer Sales Manager Therapist, All Other Scientist Toxicoligist Secondary School Teacher, Except Special And Vocational Education Training And Development Manager Securities, Commodities, Or Financial Services Sales Agent Training And Development Specialist Ship Engineer Urban Or Regional Planner Social Sciences Teacher, Postsecondary, All Other Veterinarian Social Scientist Or Related Worker, All Other Vice President Social Work Teacher, Postsecondary Vocational Education Teacher, Middle School Social Worker Vocational Education Teacher, Postsecondary Social Worker, All Other Vocational Education Teacher, Secondary School Sociologist Writer And Author Sociology Teacher, Postsecondary Zoologist Or Wildlife Biologist

CALIFORNIA SECTION D PAGE 04 APRIL 2012

LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

27. Sponsored Alumni Groups Any named insured that is a member of one of the participating Sponsored Alumni Groups listed below, will be eligible to have their applicable rates reduced by 10% (Rate Factor .90) for all motor vehicle policies held by the named insured. If the insured qualifies for any combination of Group Saving Plus discount, Educators/Corporate & Technical Professionals discount, and/or Sponsored Alumni Group discount, the maximum individual discount amount will be applied. When an insured becomes eligible for the Persistency Discount, they will move into the Basic rating program if it offers a lower rate.

Abraham Baldwin Agricultural College Alumni Association Avila University Alumni Association Alabama A&M University Alumni Babson College Alumni

Albany State University Alumni Association Ball State University Alumni Association Albert Einstein College of Medicine Alumni Association Bard College Alumni Association Albright College Alumni Association Barry University Alumni Association

Alderson-Broaddus College Alumni Association Baruch College Alumni Association Alpha Tau Omega Fraternal Alumni Association Baylor Alumni Association Alumnae Association of Mt. Holyoke College Becker College Alumni Association Alumni And Friends of The College of Visual Arts Bemidji State University Alumni Association Alumni And Friends of The London School of Economics Benedict College National Alumni Association Alumni Association of Case Western Reserve University Benedictine University - Springfield Alumni Association Alumni Association of FIT (Fashion Institute of Tech.) Benedictine University Alumni Association Alumni Association of Georgia Highlands Bennett College Alumnae Association Alumni Association of The City College of New York Bentley University Alumni Association Alumni Association of The University of Colorado Berkeley College Alumni Association Alumni Association of The University of Michigan Berklee College of Music Alumni Association Alumni of The Juilliard School Beth Israel Medical Center Alumni Association Alvernia University Alumni Association Bethune-Cookman University National Alumni Association Alverno College Alumni Association Biola University Alumni Association American International College Alumni Association Bloomfield College Alumni Anderson University Alumni Association Bloomsburg University of PA Alumni Association Andrews University Alumni Association Bob Jones University Alumni Association Angelo State University Alumni Association Boise State Alumni Association Antioch University New England Alumni Association Boston College Alumni Association Appalachian Alumni Association Boston University Alumni Aquinas College Alumni Association Bowling Green State University Alumni Association Argosy University Alumni Association Bradley University Alumni Association Arizona State University Alumni Association Brandeis University Alumni Association Ashland University Alumni Association Brewster Academy Alumni Association Atlantic Union College Alumni Association Briarcliffe College Alumni Association Auburn Alumni Association Bridgewater State University Alumni Association Audrey Cohen College Alumni Association Brigham Young University Alumni - Hawaii Augusta State University Alumni Association Brigham Young University Alumni Association Austin Peay State University Alumni Association Brooklyn College Alumni Association Averett University Alumni Association Brown Alumni Association

CALIFORNIA SECTION D PAGE 05a September 2018 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Bryan College Alumni Association Cleary University Alumni Association Bryn Mawr Alumnae Association Cleveland State Alumni Association Bucknell University Alumni Association Coastal Carolina University Alumni Association Butler University Alumni Association Colby-Sawyer College Alumni Association Cabrini College Alumni Association College of Charleston Alumni Association Cal Alumni Association College of New Jersey Alumni Association Cal Poly Pomona Alumni Association College of Saint Benedict Alumnae Association California Baptist University Alumni Association College of Saint Elizabeth Alumni California College of The Arts Alumni Association College of St. Joseph Alumni Association California State University Alumni Association College of Staten Island Alumni Association California State University East Bay Alumni Association Colorado School of Mines Alumni Association California State University, Stanislaus Alumni Colorado State University Alumni Association California Univ. of Pennsylvania Alumni Association Columbia College Chicago Alumni Association Cal-Poly San Luis Obispo Alumni Association Columbia Southern University Alumni Association Cambridge College Alumni Association Columbia University Alumni Association Campbellsville University Alumni Columbia University Business School Club Capitol College Alumni Association Columbus State University Alumni Association Carnegie Mellon University Alumni Association Coppin State University Alumni Association Castleton State College Alumni Association Corban University Alumni Cazenovia College Alumni Association Cornell Alumni Association Cedar Crest College Alumnae Association Cornell University School of Medicine Alumni Association Centenary College Alumni Cornerstone University Alumni Association Central Bible College Alumni Association Crown College Alumni Association Central Connecticut State University Alumni Association CSU - Monterey Bay Alumni Association Central Michigan University Alumni Association CSU Bakersfield Foundation Central MO State Univ. Alumni Association CSU Dominguez Hills Alumni Association Central Penn College Alumni Association CSU Fullerton Alumni Association Central State University National Alumni Association CSU Long Beach Alumni Association Central Washington Univ. Alumni Association CSU Los Angeles Alumni Association Chapman University Alumni Association CSU Northridge Alumni Association Charter Oak Alumni Association CU Denver Alumni Association Chester College Alumni Association D' Youville College Alumni Association Chicago State University Alumni Association Daemen College Alumni Association Chico State Alumni Association Daniel Webster College Alumni Association Chinese Students And Scholars Association, USC Davenport University Alumni Association Christopher Newport University Alumni Association Dean College Alumni Association Cincinnati Christian University Alumni Association Delaware State University Alumni Association Clarion University Foundation Inc. Delaware Valley College Alumni Association Clark Atlanta Alumni Association Derryfield School Alumni Group Clayton State University Alumni Association Devry University, Inc (Devry Univ. Alumni Assoc)

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LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Dixie State College Alumni Florida State University Alumni Association Dominican College Alumni Association Fordham University Alumni Association Dowling College Alumni Association Fort Hays State University Alumni Association Drake University Alumni Association Fort Lewis College Foundation Drew University Alumnae Association Fortis Institute Alumni Association Drexel University General Alumni Association Framingham State University Alumni Association Duquesne University Alumni Association Franklin & Marshall College Alumni Association East Carolina Alumni Association Franklin Pierce University Alumni Association East Central University Alumni Association Franklin W. Olin College of Engineering Alumni Association East Stroudsburg University Alumni Association Freed-Hardeman University Alumni Association East Texas Baptist Alumni Association Fresno State Alumni Association Eastern Connecticut State University Alumni Association Friends of The Notre Dame Alumni Association Eastern Illinois University Alumni Association Friends of The University of Minnesota Alumni Association Eastern Kentucky University Alumni Association Gainesville State College Alumni Association Eastern Michigan University Alumni Association Geneva College Alumni Association Eastern Nazarene Alumni Association George Fox University Alumni Association Eastern New Mexico University Alumni Association George Mason University Alumni Association Eastern Oregon University Alumni Association George Washington University Alumni Association Eastern University Alumni Association Georgetown University Alumni Association Eastern Washington University Alumni Association Georgia College & State University Alumni Association Eckerd College Alumni Association Georgia State Alumni Association Edgewood College Alumni Association Georgia Tech Alumni Association Edinboro University Alumni Association Georgian Court University Alumni Association Elizabethtown College Alumni Association Gonzaga University Alumni Association Elms College Alumni Association Grambling State University Alumni Association Emerson College Alumni Grand Canyon University Alumni Association Emory Alumni Association Grand Valley State Alumni Association Emporia State University Alumni Association Great Basin College Alumni Association Endicott College Alumni Association Great Lakes Christian College Alumni Association Episcopal Divinity School Alumni Association Green Mountain College Alumni Eugene Bible College Alumni Association Gustavus Adolphus College Alumni Association Fairleigh Dickinson University Alumni Association Gwynedd Mercy College Alumni Association Fayetteville State University Alumni Hellenic College Alumni Association Felician College Alumni Association Hilbert College Alumni Association Ferris State University Alumni Association Hiram College Alumni Relations Fisher College Alumni Association Hofstra University Office of Alumni Relations Fisk University Alumni Association Holy Cross Alumni Association Fitchburg State University Alumni Association Holy Family University Alumni Association Florida A&M Alumni Association Hospital For Joint Diseases/Special Surgery Alumni Florida Gulf Coast University Alumni Association Houghton College Alumni Association

CALIFORNIA SECTION D PAGE 05c MAY 2012 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Houston Baptist University Alumni Association La Roche College Alumni Association Humboldt State University Alumni Association Lafayette Alumni Association Hunter College Alumni Lander University Alumni Husson University Alumni Association Langston University Alumni Affairs Huston-Tillotson Alumni Affairs Lasalle University Alumni Association Idaho State University Alumni Association Lawrence Technological University Alumni Association Immaculata University Alumni Association Le Moyne College Alumni Association Immaculate Heart Academy Alumni Association Lehigh University (Alumni Association) Independent University Alumni Association At Lowell Inc Lehman College Alumni Association Indiana Institute of Technology Alumni Association Lesley Alumni Indiana State University Alumni Association Lewis University Alumni Association Indiana University Alumni Association Lewis-Clark State College Alumni Association Indiana University of PA Alumni Association Liberty University Alumni Association Indiana Wesleyan University Alumni Association Limestone College Alumni Association Inroads, Inc. Linfield College Alumni Association Iona College Alumni Association Lock Haven University Foundation Iowa State University Alumni Association Longwood University Alumni Association Ithaca College Alumni Association Louisiana College Alumni Association Jacksonville State Alumni Association Louisiana State Univ. At Shreveport Alumni Association James Madison University Alumni Association Loyola Marymount Alumni Association Javelina Alumni Association Loyola University Chicago Alumni Relations Jefferson College of Health Sciences Alumni Association Loyola University Maryland Alumni Association John Carroll University Alumni Association Loyola University New Orleans-Alumni John F. Kennedy University Alumni Association LSU Alumni Association Johns Hopkins University Alumni Association Lyndon State College Alumni Association Johnson & Wales University Alumni Association Maine College of Art Alumni Association Johnson C. Smith University National Alumni Association Manhattan College Alumni Society Judson University Alumni Association Manhattanville College Alumni Association Kansas State University Alumni Association Mannes College (Alumni) Kean University Alumni Association Manor College Alumni Association Keene State Alumni, Faculty, & Staff Mansfield University Foundation Kennesaw State University Alumni Association Maranatha Baptist Bible College Alumni Association Kent State University Alumni Association Marian University Alumni Association Kentucky Christian University Alumni Marlboro College Alumni Kentucky Wesleyan College Alumni Association Mars Hill College Alumni Association Kettering / GMI Univ. Alumni Association Marshall University Alumni Association Keystone College Alumni Association Marylhurst Alumni Association King's College Alumni Association Marymount Manhattan College Alumni Association Kutztown University Alumni Association Marywood University Alumni Association Kuyper College Alumni Association Massachusetts College of Art Alumni Association

CALIFORNIA SECTION D PAGE 05d MAY 2012 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Massachusetts College of Liberal Arts Alumni Association National Alumni Association of St. Augustine's College Master's College Alumni Association National Alumni Association of The University of Alabama Medgar Evers College - Alumni Association National Taiwan University Alumni Association Mercy College Alumni Association NC State Alumni Association Meredith College Alumnae Association Neoucom Alumni Association Methodist University Alumni Association New England Conservatory Alumni Association Metro State College Alumni Association New England Institute of Technology Alumni Association Metropolitan College of NY Alumni Association New Hampshire Institute of Art Alumni Association Metropolitan State University Alumni Association New Mexico Highlands University Alumni Association Miami University of Ohio Alumni Association New Mexico State University Alumni Association Michigan State University Alumni Association New York City College of Technology Alumni Association Michigan State University Alumni Association New York Hospital Alumni Council Michigan Tech University Alumni Association New York Institute of Technology Alumni Millersville University of Pennsylvania Alumni Association New York Pui Ying Alumni Minnesota State University Mankato Foundation New York University Alumni Misericordia University Alumni Association New York University School of Medicine Alumni Association Mississippi State University Alumni Association Niagara University Alumni Association Missouri Baptist University Alumni NJIT - New Jersey Institute of Technology Alumni MIT Sloan Alumni Club No. NV Saint Mary's Alumni Association Chapter Molloy College (Alumni) North Carolina A & T State University Alumni Association Monmouth University Alumni Association North Carolina Central University Alumni Association Monroe College Alumni Association North Dakota State University Alumni Association Montana State University Alumni Association North Georgia College And State University Alumni Montana Tech Alumni Association North Greenville University Alumni Association Montclair State University Alumni Association Northeastern State University Alumni Association Montefiore Medical Center Alumni Association Northeastern University Alumni Association Montgomery College Alumni Association Northern Alumni Association of Montana State Montreat College Alumni Association Northern Arizona University Alumni Association Moravian Alumni Association Northern Kentucky University Alumni Association Morehead State University Alumni Northern Michigan University Alumni Association Morehouse College National Alumni Association Northwest Christian University Alumni Association Morris Brown College Alumni Association Northwest Missouri State University Alumni Association Mount Sinai School of Medicine Alumni Association Northwest Nazarene College Alumni Association Mount St. Mary's College Alumni Association Northwest University Alumni Association Mount Vernon Nazarene University Alumni Association Northwestern Alumni Association Mountain State University Alumni Association Notre Dame Club of Portland Mt. St. Mary College Alumni Association NY College of Podiatric Alumni Association Muhlenberg College Alumni Association Nyack College Alumni Association Naropa Institute Alumni Association Oakland University Alumni Association National Alumnae Association of Spelman College Occidental College Alumni Association

CALIFORNIA SECTION D PAGE 05e MAY 2012 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Ohio Christian University Alumni Association Rider University Alumni Association Ohio Dominican University Alumni Association Robert Morris University Alumni Association Ohio University Alumni Association Rochester Institute of Tech. Alumni Association Ohio Valley University Alumni Association Roger Williams University Alumni Association OHSU School of Nursing Alumni Association Rosemont College Alumni Oklahoma City University Alumni Association Rowan University Alumni Association Oklahoma State University Alumni Association Russell Sage College Alumnae Association Oral Roberts University Alumni Foundation Rutgers University Alumni Association Oregon Institute of Technology Alumni Association Sacramento State Alumni Association Oregon State University Alumni Association Sacred Heart University Alumni Association Otterbein University Alumni Association Saginaw Valley State University Alumni Association Pacific Union College Alumni Association Saint Francis University Alumni Association Parsons School of Design Alumni Association Saint John's University Alumni Association Patrick Henry College Alumni Association Saint Joseph (CT) College Alumnae Association PCOM-Philadelphia College of Osteopathic Medicine Alumni Association Saint Joseph's College of Maine Alumni Association Peace College Alumnae Association Saint Louis University Alumni Penn State Alumni Association Saint Mary's College of California Alumni Pepperdine University Alumni Association Saint Peter's College Alumni Association Philadelphia University Alumni Association Salem State University Alumni Association Pine Manor College Alumni Association Salt Lake Bible College Alumni Association Pinkerton Academy Alumni Association Salus University Alumni Association Pitt Alumni Association Salve Regina University Alumni Pitzer College Alumni Association Sam Houston State University Alumni Association Plymouth State University Alumni Association San Diego State University Alumni Association Point Park University Alumni Association San Francisco State University Alumni Association Polytechnic Institute of NYU Association Alumni Association San Jose State University Alumni Association Portland State University Alumni Association Sarah Lawrence College Alumni Association Prairie View A&M University National Alumni Association Savannah State University National Alumni Association Pratt Institute Alumni School of The Visual Arts Alumni Association Presbyterian College Alumni Seton Hall University Alumni Association Prescott College Alumni Association Shaw University National Alumni Association Providence College Alumni Association SHC National Alumni Association Purdue Alumni Association Shippensburg University Alumni Association Queens College Alumni (CUNY) Shorter University Alumni Association Queens University of Charlotte Alumni Association Sierra Nevada College Alumni Association Ramapo College Alumni Association Sigma Phi Epsilon Alumni Association Regent University Alumni Association Simmons Alumnae Association Rensselaer Alumni Association Simpson University Alumni Association Rhode Island College Alumni Association Slippery Rock University Alumni Association Richmont Graduate University Alumni Smith College Alumnae Association

CALIFORNIA SECTION D PAGE 05f MAY 2012 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Sonoma State University Alumni Association SUNY College At Oneonta Alumni Association South Carolina State University National Alumni Association SUNY College of Environmental Sciences Alumni Association South Dakota State University Alumni Association SUNY Cortland College Alumni Association Southeast Missouri State University Alumni Association SUNY Delhi Alumni Association Southern CT State University Alumni Association SUNY Farmingdale Alumni Association Southern Illinois University Alumni Association SUNY Fredonia Alumni Association Southern Illinois University Edwardsville Alumni Association SUNY Geneseo Alumni Association Southern New Hampshire University Alumni SUNY Health Science Ctr - Nursing Alumni Southern Oregon Univ. Alumni Association SUNY Health Science Ctr.- Chp Alumni Association Southern Polytechnic State University Alumni Association SUNY Institute of Technology Alumni Association Southern University Alumni Federation SUNY Morrisville State College Alumni Association Southern Utah University Alumni Association SUNY New Paltz Foundation (Alumni) Southwest College of Naturopathic Medicine Alumni SUNY Oswego Alumni Assoc, Inc. Southwest Minnesota State University Alumni Association SUNY Plattsburgh Alumni Association Southwestern Adventist University Alumni Association SUNY Potsdam Alumni Association Southwestern Christian University Alumni Association SUNY Purchase College Alumni Association Southwestern Law School Alumni SUNY Stony Brook Alumni Association Southwestern Oklahoma State University Alumni Association Syracuse University Alumni Association Spalding University Alumni Tarleton Alumni Association Spring Arbor University Alumni Association Temple University Alumni Association St. Bonaventure University Alumni Association Tennessee Tech University Alumni Association St. Catharine College Alumni Association Tennessee Temple University Alumni Association St. Cloud State Alumni Tennessee Wesleyan College Alumni Association St. John Fisher Alumni Association Texas A & M Univ - Corpus Christi Alumni Association St. John's University Alumni Association Texas A&M - Texarkana Alumni Association St. Joseph's University Alumni Association Texas A&M University - Commerce Alumni Association St. Louis College of Pharmacy Alumni Association Texas Southern University National Alumni Association St. Norbert College Alumni Association Texas State Alumni Association St. Petersburg College Alumni Association Texas Tech Alumni Association St. Thomas Aquinas College Alumni Association Texas Wesleyan University Alumni Association Stephen F. Austin University Alumni Association The Alumni Association of Gannon University Suffolk University Alumni Association The Alumni Association of The University of Kansas SUNY Albany Alumni Association The Alumni Society of The University of Scranton SUNY Alfred State College Alumni Association The Association of Former Students Texas A&M SUNY At Old Westbury Alumni Association The Boston Conservatory Alumni Association SUNY Binghamton University Alumni Association The Catholic University of America Alumni Association SUNY Buffalo State Alumni Association The College of Idaho Alumni Association SUNY Canton Alumni Association The College of Saint Rose Alumni Association SUNY Cobleskill Alumni Association The Duke Alumni Association SUNY College At Brockport Alumni Association The General Theological Seminary Alumni Association

CALIFORNIA SECTION D PAGE 05g MAY 2012 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

The Medaille College Alumni Association University of Arkansas Alumni Association The New School (Alumni) University of Arkansas At Little Rock Alumni Association The Ohio State University Alumni Association University of Arkansas Fort Smith Alumni Association The Richard Stockton College of New Jersey Alumni University of Bridgeport Alumni Association The University of Houston Alumni Association University of Central Arkansas Alumni Association The University of Mississippi Alumni Association University of Central Oklahoma Alumni Association The University of Southern Mississippi Alumni Association University of Charleston, WV Alumni Association The University of Texas At Arlington Alumni Association University of Chicago Alumni Association Theta Chi Fraternity Alumni Association University of Colorado CO Springs Alumni Thiel College Alumni Association University of Connecticut Alumni Association Thomas M. Cooley Law School Alumni Association University of Dallas Alumni Association Thomas More College Alumni Association University of Dayton - National Alumni Association Toccoa Falls Alumni Association University of Delaware Alumni Association Towson University Alumni University of Denver Alumni Association Transylvania University Alumni Association University of Detroit Mercy Alumni Association Trinity Christian College Alumni Association University of Evansville Alumni Association Troy University Alumni Association University of Georgia Alumni Tufts University Alumni Association University of Hartford Alumni Association Tulane Alumni Association University of Hawaii Alumni Association TWU Former Students Association University of Idaho Alumni Association U.Va. Alumni Association University of Illinois Alumni Association Uahuntsville Alumni Association University of Iowa Alumni Association UC Davis Cal Aggie Alumni Association University of Kentucky Alumni Association UCF Alumni Association (University of Central FL) University of Louisiana Monroe Alumni Association UCLA Alumni Association University of Louisville Alumni Association UCR Alumni Association University of Maine Alumni Association UCSC Alumni Association University of Memphis Alumni Association UCSD Medical Center Housestaff Alumni Association University of Miami Alumni Association UMass Alumni Association University of Minnesota - Crookston Alumni Association UMBC Alumni University of Minnesota Alumni Association UNC Asheville Alumni Association University of Minnesota Duluth Alumni Association Union College Alumni Association University of Missouri - Rolla Alumni Association United Wesleyan College Alumni Association University of Missouri - St. Louis Alumni Association Unity College Alumni Association University of Missouri Alumni Association Univ of Missouri Kansas City Alumni Association University of Mobile Alumni Association Univ. North Carolina - Charlotte Alumni Association University of Montana Alumni Association Univ. of South Carolina Alumni Association University of NC At Greensboro Alumni Affairs University of Al Birmingham Nat'L Alumni Society University of Nebraska At Lincoln Alumni Association University of Alaska Alumni Association University of Nebraska At Omaha Alumni Association University of Arizona Alumni Association University of New Hampshire Alumni

CALIFORNIA SECTION D PAGE 05h MAY 2012 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

University of New Haven Alumni Association USC Alumni Association University of New Mexico Alumni Association Utah State University Alumni Association University of North Alabama Alumni Association Utah Valley University Alumni Association University of North Carolina Alumni - Chapel Hill Valdosta State University Alumni Association University of North Dakota Alumni Association Valley Forge Christian College Alumni Association University of North Florida Alumni Association Valparaiso University Alumni Association University of North Texas Alumni Association Vermont Law School Alumni Association University of Northern Colorado Alumni Association Vermont Technical College Alumni Association University of Northern Iowa Alumni Association Villanova University Alumni Association University of Notre Dame Alumni Association Virginia Commonwealth University Alumni Association Virginia Commonwealth University Medical College Alumni University of Oklahoma Alumni Association Association University of Oregon Alumni Association Virginia Tech Alumni Association University of Pennsylvania Alumni Association Virginia Union Univ. Alumni Association University of Phoenix Alumni Association Virginia Union University Alumni Relations University of Portland Alumni Virginia Wesleyan Alumni Association University of Rhode Island Alumni Association Wagner College Alumni University of Rio Grande Alumni Association Wake Forest University Alumni Association University of San Diego Alumni Association Walsh County Alumni Association University of South Alabama Alumni Association Warner Pacific College Alumni University of South Dakota Alumni Washington & Jefferson College Alumni Association University of South Florida Alumni Association Wayland Baptist University Alumni Association University of Southern Maine Alumni Wayne State University Alumni Association University of St Francis Alumni Association Weber State University Alumni Association University of Tampa National Alumni Association Webster University Alumni Association University of Tennessee Alumni Association Wentworth Institute Alumni University of Texas Alumni Association Wesley College Alumni Association University of The Arts Alumni Association West Chester University Alumni Association Endowment University of The District of Columbia Alumni Association West Liberty University Alumni Association University of The Incarnate Word Alumni Association West Texas A&M University Alumni Association University of The Pacific Alumni Association West VA College of Osteopathic Medicine Alumni University of Toledo Alumni Association West Virginia State College Alumni Affairs Office University of TX At San Antonio Alumni Association West Virginia University Alumni Association University of Utah Alumni Association Western CT State Univ. Alumni Association University of Washington Alumni Association Western Illinois University Alumni Association University of West Georgia Alumni Association Western International University Alumni Network University of Wisconsin Alumni Association Western Kentucky University Alumni Association University of Wyoming Alumni Association Western Michigan University Alumni Association UNLV Alumni Association Western New England College Alumni Association Urbana University Alumni Association Western Oregon University Alumni Association Ursuline Academy Alumnae Western State University Alumni Association

CALIFORNIA SECTION D PAGE 05i MAY 2012 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Western Washington University Alumni Association Jackson State University Alumni Westfield State College Alumni Association Maryland Institute College of Art Alumni Association Westminster Choir College of Rider University Alumni National University Alumni Association Wheeling Jesuit University Alumni Association Park University - Alumni Association Whittier College Alumni Association University at Buffalo Alumni Association Widener University Alumni Association University of Maine Augusta Alumni Association Wilkes University Alumni Association University of Vermont Alumni Association Willamette University Alumni Association Antioch University Alumni William Carey University Alumni Association Frostburg State University William Paterson University Alumni Association Grand Valley State University Alumni Association

Williamson Christian College Alumni Association Harford Community College Alumni Association

Wilmington University Alumni Association Midway College Alumni Winona State University Alumni Society Rollins College Alumni Association Wisconsin Alumni Association Rollins College Alumni Association Worcester Poly Tech Alumni Association Southeast Chapter of KNUST Alumni Association Worcester State College Alumni Association University of Louisiana at Lafayette Alumni Association Wright State University Alumni Association University of Southern Indiana AA WV Tech Alumni Association Washburn Alumni Association Xavier University National Alumni Association Creighton Alumni York College of PA Alumni Association Doane College Alumni Youngstown State University Office of Alumni Affairs East Tennessee State University National Alumni Association Auburn University - Montgomery Georgetown College Alumni Association - KY College Campbell University Alumni Association Harcum College Alumni Campbell University College of Pharmacy & Health Hood College Alumni Association City University of Seattle Alumni Association Lake Superior State University Alumni Association Colorado College Alumni Association Lasell College Alumni Association Georgia Southwestern State University Murray State University Alumni Association Minnesota State University Moorhead Alumni Association North Carolina Wesleyan College Alumni Association Roberts Wesleyan College Alumni Association Our Lady of the Lake Alumni Siena College Alumni Paul Smith's College The Cooper Union Alumni Association Presentation College Alumni Association University of Rochester Alumni Association Roosevelt University Alumni University of Saint Thomas Alumni Association Seton Hill University Alumni Association Washington State University Alumni Association Southeastern Louisiana University Alumni Association William Jessup University Alumni Association Sul Ross State University Alumni Wofford College Alumni Association U of WI - Stevens Point AA Adelphi University Alumni University of Central Missouri Alumni Association Anna Maria College Alumni Association Virginia International University California Northstate University Alumni Wichita State University Alumni Furman University Alumni Association Aracadia University Alumni

CALIFORNIA SECTION D PAGE 05j April 2015 LIBERTY MUTUAL INSURANCE GROUP AUTOMOBILE RATING MANUAL MISCELLANEOUS SURCHARGES AND DISCOUNTS

Columbia Southern University

Hartwick College Alumni

Mercyhurst University Alumni Association

New Mexico Tech Alumni

Saint Anselm College Alumni Association

Western Governors University

Western Governors University Alumni Association

Albany College of Pharmacy Alumni

Marymount University Alumni Association

Neumann University Alumni Association

Nicholls State University Alumni Federation

Pacific University Alumni Association

Oklahoma Christian University Alumni

Springfield College Alumni Association

College of New Rochelle

Southeastern Oklahoma State University Alumni

Delta State Univ Alumni

Huston-Tillotson University AA

Pittsburg State University Alumni

The University Of Findlay Alumni Association

Tiffin University Alumni Association

John Jay College Foundation, Inc. (Alumni)

Arcadia University Alumni

New Jersey City University Foundation, Inc.

Azusa Pacific University Alumni Association

Gettysburg College Alumni Association

Georgia Southern University

Frontier Nursing University Alumni

Malone University

Seattle University Alumni Association

CALIFORNIA SECTION D PAGE 05k August 2016

PROOF OF SERVICE 1 2 State of California, City of Los Angeles, County of Los Angeles

3 I am employed in the City of Los Angeles and County of Los Angeles, State of California. I am over the age of 18 years and not a party to the within action. My business address is 6330 San Vicente 4 Blvd., Suite 250, Los Angeles, California 90048, and I am employed in the city and county where this service is occurring. 5 6 On February 21, 2019, I caused service of true and correct copies of the document entitled

7 STOP DISCRIMINATORY AUTO INSURANCE OVERCHARGES: PETITION FOR RULEMAKING PURSUANT TO GOVERNMENT CODE SECTION 11340.6 8 upon the persons named in the attached service list, in the following manner: 9

10 1. If marked HAND DELIVERED, by personally delivering copies to the person served at the listed address. 11 2. If marked EMAIL, by electronic mail transmission this date to the email address stated. 12 3. If marked U.S. MAIL or OVERNIGHT, by placing this date for collection for regular or overnight 13 mailing true copies of the within document in sealed envelopes, addressed to each of the persons 14 so listed. I am readily familiar with the regular practice of collection and processing of correspondence for mailing of U.S. Mail and for sending of Overnight mail. If mailed by U.S. 15 Mail, these envelopes would be deposited this day in the ordinary course of business with the U.S. Postal Service. If mailed Overnight, these envelopes would be deposited this day in a box or 16 other facility regularly maintained by the express service carrier or delivered this day to an authorized courier or driver authorized by the express service carrier to receive documents, in the 17 ordinary course of business, fully prepaid. 18 4. If marked FAX SERVICE, by fax transmission this date to the FAX number stated to the 19 person(s) named. Based on an agreement of the parties to accept service by fax transmission, I faxed the documents to the persons at the fax numbers listed below. No error was reported by the 20 fax machine that I used. A copy of the record of the fax transmission which I printed out is 21 attached. I declare under penalty of perjury that the foregoing is true and correct. Executed on February 21, 22 2019 at Los Angeles, California. 23

24 ______Kaitlyn Gentile 25 26 27 28 1

PROOF OF SERVICE

Service List 1

2 The Honorable Ricardo Lara FAX Insurance Commissioner U.S. MAIL 3 State of California OVERNIGHT MAIL 300 Capital Mall, Suite 1700 HAND DELIVERED 4 Sacramento, CA 95814 EMAIL 5

6 Geoff Margolis FAX 7 Deputy Commissioner and Special Counsel U.S. MAIL California Department of Insurance OVERNIGHT MAIL 8 300 Capitol Mall, 17th Floor HAND DELIVERED Sacramento, CA 95814 EMAIL 9 Tel. (916) 492-3574 Fax (916) 445-5280 10 [email protected] 11

12 Edward Wu FAX Staff Counsel and Public Advisor U.S. MAIL 13 Office of the Public Advisor OVERNIGHT MAIL California Department of Insurance HAND DELIVERED 14 300 South Spring Street, 12th Floor EMAIL 15 Los Angeles, CA 90013 Tel. (213) 346-6635 16 Fax (213) 897-9241 [email protected] 17

18 Joel Laucher FAX 19 Special Consultant U.S. MAIL California Department of Insurance OVERNIGHT MAIL 20 45 Fremont Street, 21st Floor HAND DELIVERED San Francisco, CA 94105 EMAIL 21 Tel. (415) 538-4381 [email protected] 22 23

24 25

26 27 28 2

PROOF OF SERVICE

EXHIBIT 3

From: Vera, Vanessa [email protected] Subject: PRA-2019-00555 (CL) Public Records Act Request Date: June 7, 2019 at 5:02 PM To: [email protected] Cc: Hein, Patricia [email protected], Lor, Chao [email protected]

Dear Mr. Flanagan,

The California Department of Insurance (Department) is in receipt of your records request below. Upon reviewing this request, we have determined that the request, as currently written, is overbroad and will be unduly burdensome on staff to search for responsive records. Please assist us with narrowing your request by providing us with the following additional information:

· The time frame(s) of the records being requested. For example, are you seeking records between January 1, 2019 to the present or another time period? · The names of the individuals and/or names of insurance companies that may have had meetings or phone conference calls with Commissioner Lara or may have paid for his travel costs. If you do not have this information, but know the subject matter of the meetings, phone conference calls, or travels, please provide us with this information.

Thank you for your attention to this matter and we look forward to hearing from you soon. If you have any questions, please do not hesitate to contact me or Attorney Chao Lor at (916) 492-3207 or by email at [email protected].

Sincerely,

Vanessa VeraVanessa Vera Legal Analyst California Department of Insurance Legal Division/Government Law Bureau 300 Capitol Mall Sacramento, CA 95814

CONFIDENTIALITY NOTICE: This communication may contain confidential and/or legally privileged information. It is solely for the use of the intended recipients(s). Unauthorized interception, review, use, or discloser is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.

From: Jerry Flanagan [mailto:[email protected]] Sent: Tuesday, June 4, 2019 1:29 PM To: Custodian of Records Subject: Public Records Act Request

Dear Custodian of Records, Dear Custodian of Records,

Please see attached.

Jerry Flanagan

Jerry Flanagan Litigation Director Consumer Watchdog Los Angeles, CA & Washington, D.C. Ofce: (310) 392-2632 Mobile: (310) 889-4912 Fax: (310) 392-8874 http://www.ConsumerWatchdog.org

Consumer Watchdog is a non-profit and non-partisan public interest organization.

PRA to CDI_Co…e 4.pdf

EXHIBIT 4

June 11, 2019

VIA EMAIL AND OVERIGHT DELIVERY

Chao Lor California Department of Insurance 300 Capitol Mall, Suite 1700 Sacramento, CA 95814 Email: [email protected] Tel.: (916) 492-3207

RE: PRA-2019-00555 (CL) Public Records Act Request

Dear Ms. Lor,

Thank you for the phone conference today regarding the above-captioned Public Records Act (“PRA”) request. We provide this response in an effort to address the Department’s concerns, as articulated in Ms. Vera’s June 7, 2019 email, that the PRA request as initially constituted would “be unduly burdensome on staff to search for responsive records.” The initial request is attached as Exhibit 1 for ease of reference.

Pursuant to Government Code section 6253, subdivision (b) of the PRA, and Article 1, section 3 of the California Constitution, Consumer Watchdog hereby requests copies of the following records:1

1. All appointment schedules, calendars, meeting logs, phone call logs, mobile phone records, and any other records relating to any meetings or phone calls (“Conferences”) between Insurance Commissioner Lara and any individuals2 who are employed by or represent the interests of one or more insurance companies or the insurance industry. This request includes, but is not limited to, records providing the identities of the individuals participating in the Conferences as well as records reflecting when and where the Conferences occurred. Item 1 seeks records from January 7, 2019 to the present.

2. All records regarding Insurance Commissioner Lara’s out-of-state travel, including the persons or entities that paid for that travel, including airfare and other transportation, hotels, meals, and entertainment. Item 2 seeks records from January 7, 2019 to the present.

1 As used in this letter, the term “records” includes writings and correspondence that are printed, typed, hand-written, facsimiles or computer-generated e-mail. 2 As used in this letter, the term “individuals” does not include those persons employed by the Department of Insurance (“Department”).

California Department of Insurance June 11, 2019 Page 2 of 3

3. All records regarding the March 21, 2019 Climate Change Petition for Rulemaking (“Climate Change Petition”) attached as Exhibit 2. Attached as Exhibit 3 is the response to the Climate Change Petition provided by the Department. Per your request, we provide the Department’s response to assist you in identifying persons at the Department who may be in possession of records pertaining to this request. Item 3 seeks records from March 21, 2019 to the present. Item 3 does not seek records subject to the attorney work product or attorney-client privileges properly invoked by the Department.

4. All records regarding the February 21, 2019 Petition for Rulemaking to ban the use of education and occupation to set insurance premiums (“Education/Occupation Petition”) attached as Exhibit 4. Attached as Exhibit 5 is the response to the Education/Occupation Petition provided by the Department. Per your request, we provide the Department’s response to assist you in identifying persons at the Department who may be in possession of records pertaining to this request. Item 4 seeks records from February 21, 2019 to the present. Item 4 does not seek records subject to the attorney work product or attorney-client privileges properly invoked by the Department.

Consumer Watchdog requests these records in an electronic format such as a Portable Document Format (“PDF”).

Any records withheld from production for inspection should be separately identified and accompanied by the claimed justification for withholding those records as required by Government Code section 6255. The justification should state the nature of the record withheld and the specific exemption under which the record is being withheld, and provide an explanation of why the public interest is served by withholding the record. We reserve the right to appeal the Department’s decision to withhold any materials.

Should you contend that a portion of a particular record is exempt from disclosure, pursuant to Government Code section 6253, subdivision (a) the exempt portion should be redacted and the remaining portion produced for inspection.

Consumer Watchdog is prepared to pay reasonable search and duplication fees in connection with this request. However, agencies have discretion to waive fees in order to provide greater access to public records pursuant to Government Code section 6253, subdivision (e). (See North Co. Parents Org. v. California Dep’t of Educ. (1994) 23 Cal.App.4th 144, 148.) As the information that is the subject of this request is of primary benefit to the public, we ask that the Department waive all search and duplication fees.

California Department of Insurance June 11, 2019 Page 3 of 3

If you have any questions regarding this PRA request, please contact me at (310) 392-2632 or [email protected].

Respectfully submitted,

Jerry Flanagan

EXHIBIT 5

July 11, 2019

VIA EMAIL AND OVERNIGHT DELIVERY

Ms. Debbie De Guzman Legal Analyst California Department of Insurance Legal Division-Government Law Bureau 300 Capitol Mall, 17th Floor Sacramento, CA 95814 [email protected]

RE: PRA-2019-00555 (CL) Public Records Act Request

Dear Ms. De Guzman,

I am writing in response to your July 5, 2019 email1 refusing to provide Insurance Commissioner Ricardo Lara’s schedule of meetings with insurance industry representatives and related documents in response to a Public Records Act (“PRA”) request submitted by Consumer Watchdog. Disclosing such public records is essential to restoring the public trust in the Office of the Insurance Commissioner in the wake of recent news reports of influence peddling involving Commissioner Lara and insurance companies regulated by the Department, behavior a Sacramento Bee editorial called “shady and suspicious.”2

1 July 5, 2019 email attached as Exhibit A. 2 Jeff McDonald, State’s Top Insurance Regulator Accepted Tens Of Thousands Of Dollars From Industry Executives, Records Show (July 7, 2019), https://www.sandiegouniontribune.com/news/watchdog/story/2019-07-05/states-top- insurance-regulator-accepted-tens-of-thousands-of-dollars-from-industry-executives- records-show; Jeff McDonald, Insurance Commissioner Will Return Funds From Companies With Ties To Industry He Regulates, San Diego Union Tribune (July 8, 2019), https://www.sandiegouniontribune.com/news/watchdog/story/2019-07-08/insurance- commissioner-will-unhand-funds-from-companies-with-ties-to-industry-he- regulates; Editorial: Insurance Commissioner Lara Never Should Have Accepted Donations From Those He Regulates, San Diego Union Tribune (July 8, 2019), https://www.sandiegouniontribune.com/opinion/editorials/story/2019-07-08/insurance- commissioner-lara-donations-insurance-companies; Hannah Wiley, Lara’s

Debbie De Guzman July 11, 2019 Page 2

As we noted in our telephonic meet and confer with your colleague Ms. Chao Lor on June 11, 2019, the Governor’s Office makes the Governor’s full calendar available to ensure public trust in the integrity of the office. Commissioner Lara should do the same. After all, as the California Supreme Court has opined, “[a]n informed and enlightened electorate is essential to a representative democracy.” (Times Mirror Co. v. Superior Court (1991) 53 Cal.3d 1325, 1328.) Moreover, the preamble of the PRA statute notes that “access to information concerning the conduct of the people’s business is a fundamental and necessary right of every person in this state.” (Gov. Code § 6250; American Civil Liberties Union Foundation v. Deukmejian (1982) 32 Cal.3d 440, 447.)

Should Commissioner Lara choose to refuse to provide his full schedule of meetings, with this letter we narrow Request No. 1 of our June 4, 2019 PRA request to seek records pertaining to the individuals and companies listed below. Though we are narrowing our PRA request in order to facilitate a prompt disclosure of records, we reserve the right to revisit the full request in order to adequately assess whether there exist other potential conflicts of interest.

As explained below, each of the individuals and companies identified in this revised request raises significant public interest issues, as it appears these individuals and companies were attempting to inappropriately influence Commissioner Lara’s decision- making on important public matters in violation of state and federal law. Specifically, by this letter Request 1 is amended as follows:

All appointment schedules, calendars, meeting logs, phone call logs, mobile phone records, and any other records relating to any meetings or phone calls (“Conferences”) between Insurance Commissioner Lara or his representatives, including staff of the Department, and the following individuals: Steven M. Menzies, Jeffrey A. Silver, Stephen Acunto, Carole Acunto, Carl DeBarbie, Theresa DeBarbrie, Sidney R. Ferenc, Jon M. McCright, Marc M. Tract, Robert L. Stafford, Justin N. Smith, Darlene Graber, and Larry R. Graber. This request also includes records of Conferences between Insurance Commissioner Lara and any individuals employed by or representing Applied Underwriters, California Insurance Company (“CIC”), Constitution Insurance Company, or Independence Holding Company (“IHC”). This request includes, but is not limited to,

‘Questionable’ Campaign Contributions, Sacramento Bee (July 10, 2019), https://www.sacbee.com/site-services/newsletters/capitol- morning/article232453557.html; Editorial: Insurance Commissioner’s Campaign Cash Scandal Raises Troubling Questions, Sacramento Bee (July 10, 2019), https://www.sacbee.com/opinion/editorials/article232509952.html.

Debbie De Guzman July 11, 2019 Page 3

records providing the identities of the individuals participating in the Conferences as well as records reflecting when and where the Conferences occurred and the topics of those Conferences. This request seeks records from January 7, 2019 to the present.

Three of the individuals listed above who have made financial contributions to Commissioner Lara’s 2022 re-election campaign—Stephen and Carol Acunto and Theresa DeBarbrie—are connected to Applied Underwriters and its subsidiary CIC. Applied Underwriters and CIC settled an enforcement action brought by the Department for “bait and switch” marketing tactics in 2017 and the companies are currently fighting legal actions brought by five other businesses it insured. Applied Underwriters and CIC are also currently undergoing a change in ownership that will require Commissioner Lara’s approval pursuant to Insurance Code section 1215.2 (“Section 1215.2”).

Steven M. Menzies is identified as the individual acquiring CIC in a document, attached as Exhibit B, filed with the Department pursuant to Section 1215.2. Mr. Menzies currently owns a minority share of Applied Underwriters and stands to gain control of the company if it is successfully spun off from Berkshire Hathaway. Mr. Menzies is also President of Constitution Insurance Company, whose directorate interlocks with Applied Underwriters and CIC, several members of which have also contributed to Commissioner Lara. Jeffrey A. Silver is identified in Exhibit B as an attorney representing Mr. Menzies in the CIC transaction and is Treasurer of Constitution Insurance Company.

Stephen Acunto is Managing Director of the Constitution Group, which wholly owns Constitution Insurance Company. Mr. Acunto is also a spokesperson for Applied Underwriters. Theresa DeBarbrie’s husband is Carl DeBarbrie, an insurance broker for Applied Underwriters and former executive with Constitution Insurance Company and CIC. Sidney R. Ferenc, Jon M. McCright, Marc M. Tract, Robert L. Stafford, and Justin N. Smith are all listed as Directors or Officers of CIC in Exhibit B.

A fourth donor to Commissioner Lara, Darlene Graber, is the wife of Larry R. Graber, who is Senior Vice President and Director of IHC. IHC is one of the largest sellers of short term “junk” health insurance in the United States.3 California banned short term insurance in 2018.4

3 Robert Pear, Trump’s Short-Term Health Insurance Policies Quickly Run Into Headwinds, N.Y. Times (Aug. 6, 2018), https://www.nytimes.com/2018/08/06/us/ politics/trump-short-term-health-plans.html 4 Catherine Ho, Defying Trump, California Legislature bans short-term health insurance, S.F. Chronicle (Aug. 20, 2018), https://www.sfchronicle.com/business/article/Defying- Trump-California-legislature-bans-13169686.php Debbie De Guzman July 11, 2019 Page 4

The public has an interest in knowing whether Commissioner Lara met with these individuals, as the campaign contributions appear to have been intended to inappropriately influence Commissioner Lara’s decision regarding the sale of Applied Underwriting and CIC. In the case of IHC, the purpose of the political contributions may have been to encourage support for IHC’s efforts to re-enter the California market. As you know, a public official may be criminally liable if he or she “asks, receives, or agrees to receive, any bribe, upon any agreement or understanding that his or her vote, opinion, or action upon any matter then pending, or that may be brought before him or her in his or her official capacity, shall be influenced thereby . . . .” (Penal Code § 68.) An elected official could also be guilty of extortion if he or she wrongfully uses his or her public position to obtain a personal benefit. (Penal Code § 518.) Similarly, pursuant to federal law, the public has the right to the “honest services” of public officials. This right is violated when a public official makes a decision that is not motivated by the public’s interest but instead by his or her personal interest. (18 U.S.C. §§ 1341, 1343, 1346.) Moreover, a public official may not make, participate in, or influence a governmental decision that will have a reasonably foreseeable and material financial effect on the official or any of the official’s financial interests. (Gov. Code §§ 87100, 87103.)

The requested records will allow the public to answer these troubling questions: 1) Did Commissioner Lara or his representatives meet or communicate with the donors, Mr. Menzies, Mr. Silver, or any other representatives of Applied Underwriters or IHC? 2) Were Applied Underwriters’ pending matters before the Department or IHC’s business in California discussed at such a meeting? 3) How, when, and where were the contributions offered (for example, at a fundraising gathering or meeting)? 4) Was there in fact no contact between Commissioner Lara or his representatives and the donors, Mr. Menzies, Mr. Silver, or any other representatives of Applied Underwriters, Constitution Insurance Company, or IHC? Full transparency is necessary to address any appearance of impropriety or undue influence and lay this matter to rest.

Your reliance on the so-called “public interest” exception to the PRA statute to withhold Commissioner Lara’s schedule is perplexing at best. You have not even attempted to demonstrate that “the public interest served by not disclosing the record clearly outweighs the public interest served by disclosure of the record.” (Gov. Code § 6255(a).) Nor can you. Moreover, concerns about chilling the “deliberative process” have no place where the public interest at stake is whether the regulated companies or Commissioner Lara violated state or federal law. (See Times Mirror Co., 53 Cal.3d at 1341.)

Debbie De Guzman July 11, 2019 Page 5

Though we dispute the applicability of the “public interest” exemption in this instance, the very California Supreme Court decision you cite in your July 5 email notes that a focused request like the one at issue here outweighs any interest in keeping public records from the public view.

[W]here the public interest in certain specific information contained in one or more of the [elected official’s] calendars is . . . compelling, [and] the specific request more focused; then, the court might properly conclude that the public interest in nondisclosure does not clearly outweigh the public interest in disclosure, whatever the incidental impact on the deliberative process.

(Times Mirror Co., 53 Cal.3d at 1345–46). In other words, the Times Mirror court

cautioned that ‘[n]ot every disclosure which hampers the deliberative process implicates the deliberative process privilege. Only if the public interest in nondisclosure clearly outweighs the public interest in disclosure does the deliberative process privilege spring into existence. The burden is on the [elected official] to establish the conditions for creation of the privilege.’

(Labor & Workforce Dev. Agency v. Superior Court (2018) 19 Cal.App.5th 12, 227, review denied (Apr. 25, 2018) [emphasis added] [quoting California First Amendment Coal. v. Superior Court (1998) 67 Cal.App.4th 159, 172–73]; see also Caldecott v. Superior Court (2015) 243 Cal.App.4th 212, 226 [holding there was “not a sufficient showing the public interest in nondisclosure outweighs the interest in disclosure. . . . Rather . . . the public interest in disclosure is compelling and is not overcome by the limited, qualified public disclosure exemption.”].) For example, in one case the Court of Appeal “conclude[d] that the public interest served by revealing the names of the pharmaceutical companies and others from whom [government officials] sought to obtain [lethal injection drugs] clearly outweighs that favoring nondisclosure.” (American Civil Liberties Union of Northern California v. Superior Court (2011) 202 Cal.App.4th 55, 77–78.)

Similarly, the other bases you cite for withholding all requested records in response to Request 1 are also inapplicable. For example, Insurance Code section 12919, which incorporates Evidence Code sections 1040 and 1041, does not prevent the requested disclosure because there is no interest in “preserving the confidentiality of the information that outweighs the necessity for disclosure in the interest of justice.” (Evid. Code § 1040.) In fact, quite the opposite is true. Equally, your email does not explain why the Department is attempting to block disclosure of the requested records under Government Code section 6254, subdivisions (d), (f), and (k), none of which appear to apply. Finally, as the request seeks records relating to Conferences between Commissioner Lara or his representatives Debbie De Guzman July 11, 2019 Page 6 and individuals not employed by the Department, the attorney-client communications and attorney work product doctrines are also improperly invoked to block disclosure of the requested records.

I also note that the Department has committed to produce additional documents responsive to other requests in our June 4, 2019 PRA request—including the sources of payees for Commissioner Lara’s out-of-state travel—but we require further explanation for your determination that such records will not be provided until August 31, 2019.

We look forward to your response. Given the importance of the requested documents to the public and the integrity of our democratic institutions, you are hereby on notice that Consumer Watchdog intends to file a lawsuit to compel production of the records (as revised by this letter) by July 31, 2019.

Respectfully submitted,

Jerry Flanagan Litigation Director (310) 392-2632

EXHIBIT A

From: De Guzman, Debbie Lynne [email protected] Subject: RE: PRA-2019-00555 (CL) Public Records Act Request Date: July 5, 2019 at 3:55 PM To: Jerry Flanagan [email protected] Cc: Lor, Chao [email protected]

Dear Mr. Flanagan,

On June 4, 2019, the California Department of Insurance (“Department”) received the above referenced Public Records Act request. On June 11, 2019, you agreed to narrow your request. On June 22, 2019, the Department advised you it would make a determination on whether it has disclosable public records on or before July 5, 2019.

Your request seeks the following records:

1. All appointment schedules, calendars, meeting logs, phone call logs, mobile phone records, and any other records relating to any meetings or phone calls (“Conferences”) between Insurance Commissioner Lara and any individuals who are employed by or represent the interests of one or more insurance companies or the insurance industry. This request includes, but is not limited to, records providing the identities of the individuals participating in the Conferences as well as records reflecting when and where the Conferences occurred. Item 1 seeks records from January 7, 2019 to the present.

2. All records regarding Insurance Commissioner Lara’s out-of-state travel, including the persons or entities that paid for that travel, including airfare and other transportation, hotels, meals, and entertainment. Item 2 seeks records from January 7, 2019 to the present.

3. All records regarding the March 21, 2019 Climate Change Petition for Rulemaking (“Climate Change Petition”). Item 3 does not seek records subject to the attorney work product or attorney-client privileges properly invoked by the Department.

4. All records regarding the February 21, 2019 Petition for Rulemaking to ban the use of education and occupation to set insurance premiums (“Education/Occupation Petition”). Item 4 does not seek records subject to the attorney work product or attorney-client privileges properly invoked by the Department.

CDI’s Response to Request 1:

There are responsive records to this request which are not being produced. These records are privileged or confidential and exempt from disclosure under Insurance Code section 12919, Government Code section 6254, subdivisions (d), (f), and (k), Evidence Code sections 1040 and 1041, and the deliberative process privilege. (See Gov. Code § 6255; see also Times Mirror Co. v. Superior Court (1991) 53 Cal.3d 1325.). To the extent there are attorney-client communications or attorney work product, these records are confidential and exempt from disclosure under the

EXHIBIT B

EXHIBIT 6

From: Lor, Chao [email protected] Subject: RE: PRA-2019-00555 (CL) Public Records Act Request --- REVISED, ignore previous Date: July 22, 2019 at 11:35 AM To: Jerry Flanagan [email protected] Cc: De Guzman, Debbie Lynne [email protected]

Hi Jerry,

For request 1, would you agree to exclude internal records and/or communica:ons rela:ng to the requested records? We appreciate you providing us with a list of individuals and insurers but by reques:ng not just Commissioner Lara’s records but also his representa:ves and other CDI employee, we will need :me to complete a search to determine if we have responsive records.

Since there are approximately 1,300 CDI employees, if there are specific CDI employees you would like for us to check for records, would you provide us with a list of names? In the mean:me, we will con:nue to conduct a reasonable search of our records and let you know within 14 days if we have responsive records to this amended request. Of course, if we complete our search sooner and find responsive public record, we will let you know when we can make them available.

For requests 3-4, would you also be willing to exclude internal records and/or communica:ons rela:ng to the two pe::ons? Similar to request 1, if you can provide us with a list of names of third par:es or insurance companies, that would help us with our search. In the mean:me, we will con:nue to review responsive records to these requests.

Thanks in advance for your courtesy and considera:on. I look forward to hearing from you soon.

Regards, Chao

From: Jerry Flanagan [mailto:[email protected]] Sent: Thursday, July 18, 2019 12:06 PM To: Lor, Chao Subject: Re: PRA-2019-00555 (CL) Public Records Act Request --- REVISED, ignore previous

Chao,

Since we keep missing each other on the phone, please send any questions you have in writing.

thanks, Jerry

Jerry Flanagan Litigation Director Consumer Watchdog Los Angeles, CA & Washington, D.C. Office: (310) 392-2632 Mobile: (310) 889-4912

EXHIBIT 7

July 23, 2019

VIA EMAIL AND OVERNIGHT DELIVERY

Ms. Chao Lor California Department of Insurance 300 Capitol Mall, Suite 1700 Sacramento, CA 95814 Email: [email protected] Tel.: (916) 492-3207

RE: PRA-2019-00555 (CL) Public Records Act Request

Dear Ms. Lor,

I write to follow up on the above-captioned Public Records Act (“PRA”) request filed with the Department by Consumer Watchdog on June 4, 2019 (“Initial Request”). As you know, Consumer Watchdog has already agreed to significantly narrow the Initial Request on two occasions in order to reduce the burden on the Department. Most recently we narrowed Request 1 relating to Commissioner Lara’s Conferences, as defined below, with insurance industry executives by specifically identifying the individuals and insurance companies for which responsive records are sought. As I pointed out in our July 11, 2019 letter, each of the individuals and companies identified in the Revised Request raise significant public interest issues, as it appears these individuals and companies were attempting to inappropriately influence Commissioner Lara’s decision- making on important public matters in violation of state and federal law.

In an email yesterday you requested that we further narrow Request 1 by

agree[ing] to exclude internal records and/or communications relating to the requested records[.] We appreciate you providing us with a list of individuals and insurers but by requesting not just Commissioner Lara’s records but also his representatives and other CDI employee [sic], we will need time to complete a search to determine if we have responsive records. Since there are approximately 1,300 CDI employees, if there are specific CDI employees you would like for us to check for records, would you provide us with a list of names?

With this letter we provide a list of Department employees for whom responsive records are sought pursuant to Request 1 as identified below. We decline to exclude non- privileged internal records and/or communications relating to Request 1. Though we are narrowing our PRA request in order to facilitate a prompt disclosure of records, we reserve the right to revisit the full request in order to adequately assess whether there exist other potential conflicts of interest.

Ms. Chao Lor July 23, 2019 Page 2 of 4

As we indicated in our July 11, 2019 letter, given the significant public interest issues at stake1 the Department must respond in writing by no later than July 31, 2019 stating whether the Department agrees to provide records in response to Request 1 as further narrowed by this letter. If the Department does not make a clear and unequivocal commitment to provide non-privileged records by July 31, 2019, we can only presume the Department is refusing to provide the records and Consumer Watchdog will be compelled to file a lawsuit to enforce the PRA.

In your email yesterday, you also requested that Consumer Watchdog narrow Requests 3 and 4 regarding the Climate Change Petition and Education/Occupation Petition, as defined below, as follows:

would you also be willing to exclude internal records and/or communications relating to the two petitions? Similar to request 1, if you can provide us with a list of names of third parties or insurance companies, that would help us with our search. In the meantime, we will continue to review responsive records to these requests.

Consumer Watchdog declines to further narrow Requests 3 and 4 as you specified in your July 22, 2019 email, as at this time we are not aware of the identities of the individuals or companies involved.

Therefore, as revised by this letter, the Initial Request is narrowed as follows. Pursuant to Government Code section 6253, subdivision (b) of the PRA, and Article 1, section 3 of the California Constitution, Consumer Watchdog hereby requests copies of the following records:2

Request 1: All appointment schedules, calendars, meeting logs, phone call logs, mobile phone records, and any other records relating to any meetings or phone calls (“Conferences”) between Insurance Commissioner Lara or his representatives, including staff of the Department, and the following individuals: Steven M. Menzies, Jeffrey A. Silver, Stephen Acunto, Carole Acunto, Carl DeBarbrie, Theresa DeBarbrie, Sidney R. Ferenc, Jon M. McCright, Marc M. Tract, Robert L. Stafford, Justin N. Smith, Darlene Graber, and Larry R. Graber. This request also includes records of Conferences between Insurance Commissioner Lara and any individuals employed by or representing Applied Underwriters, California Insurance Company (“CIC”), Constitution Insurance Company, or Independence Holding Company (“IHC”). This request specifically relates to the following Department staff: the Executive Office staff, all Deputy

1 See, e.g., Editorial: A cloud of suspicion hangs over state insurance commissioner. Can he clear the air?, Sacramento Bee (July 23, 2019), https://www.sacbee.com/opinion/editorials/article232988522.html. 2 As used in this letter, the term “records” includes writings and correspondence that are printed, typed, hand-written, facsimiles or computer-generated e-mail. Ms. Chao Lor July 23, 2019 Page 3 of 4

Commissioners, and the Government Law Bureau.3 Individuals in these positions shall be prioritized, however this request also includes any Department staff involved in any decisions or proceedings involving Applied Underwriters, CIC, or IHC, including but not limited to decisions or proceedings at the Administrative Hearing Bureau or pursuant to Insurance Code section 1215.2. This request includes, but is not limited to, records providing the identities of the individuals participating in the Conferences as well as records reflecting when and where the Conferences occurred and the topics of those Conferences. This request seeks records from January 7, 2019 to the present. Request 1 does not seek records subject to the attorney work product or attorney-client privileges properly invoked by the Department.

Request 2: All records regarding Insurance Commissioner Lara’s out-of-state travel, including the persons or entities that paid for that travel, including airfare and other transportation, hotels, meals, and entertainment. Request 2 seeks records from January 7, 2019 to the present.

Request 3: All records regarding the March 21, 2019 Climate Change Petition for Rulemaking (“Climate Change Petition”). Per your request, we have provided the Department’s response to the Climate Change Petition in order to assist you in identifying persons at the Department who may be in possession of records pertaining to this request. Request 3 seeks records from March 21, 2019 to the present. Request 3 does not seek records subject to the attorney work product or attorney-client privileges properly invoked by the Department.

Request 4: All records regarding the February 21, 2019 Petition for Rulemaking to ban the use of education and occupation to set insurance premiums (“Education/Occupation Petition”). Per your request, we have provided the Department’s response to the Education/Occupation Petition in order to assist you in identifying persons at the Department who may be in possession of records pertaining to this request. Request 4 seeks records from February 21, 2019 to the present. Request 4 does not seek records subject to the attorney work product or attorney-client privileges properly invoked by the Department.

Regarding Request 2, we require further explanation for your determination that responsive records will not be provided until August 31, 2019.

3 For ease of reference, please find the Department’s 2017 Organization Chart on page 15 of its 2017 annual report, available here: http://www.insurance.ca.gov/0400-news/0200- studies-reports/0700-commissioner-report/upload/2017-Annual-Report-of-the- Commissioner.pdf. Note that the Executive Office staff is identified in the Organization Chart under the heading “Insurance Commissioner.” Ms. Chao Lor July 23, 2019 Page 4 of 4

Consumer Watchdog requests these records in an electronic format such as a Portable Document Format (“PDF”).

Any records withheld from production for inspection should be separately identified and accompanied by the claimed justification for withholding those records as required by Government Code section 6255. The justification should state the nature of the record withheld and the specific exemption under which the record is being withheld and provide an explanation of why the public interest is served by withholding the record. We reserve the right to appeal the Department’s decision to withhold any materials.

Should you contend that a portion of a particular record is exempt from disclosure, pursuant to Government Code section 6253, subdivision (a) the exempt portion should be redacted and the remaining portion produced for inspection.

Consumer Watchdog is prepared to pay reasonable search and duplication fees in connection with this PRA request. However, agencies have discretion to waive fees in order to provide greater access to public records pursuant to Government Code section 6253, subdivision (e). (See North Co. Parents Org. v. California Dep’t of Educ. (1994) 23 Cal.App.4th 144, 148.) As the information that is the subject of this request is of primary benefit to the public, we ask that the Department waive all search and duplication fees.

If you have any questions regarding this PRA request, please contact me at (310) 392-2632 or [email protected].

Respectfully submitted,

Jerry Flanagan

EXHIBIT 8

RICARDO LARA CALIFORNIA INSURANCE CO MMISS IONER

September 13, 2019

Jerry Flanagan ([email protected])

Re : Public Records Act Request PRA-2019-00555

Dear Mr. Flanagan:

This letter is in reply to your email request received on September 5, 2019. The Department of Insurance is responding to your request by providing the calendared meetings of Commissioner Lara from January 7, 2019 through August 31 , 2019.

Please note that Commissioner Lara's official calendar is not kept in a traditional appointment book or calendar. Rather, the Commissioner's schedule is managed by means of a computer application and details of the meetings (e.g. staffing and location) often change several times in advance of the events planned for any given day. Both internal and external meetings and certain other activities planned in advance appear on the attached calendar, which may or may not be updated subsequently in the event a scheduled meeting does not occur as scheduled.

The attached calendar does not document every activity of the Commissioner or every person he met with in his official capacity as Commissioner. Certain information is exempt from disclosure and for that reason will not be provided. For example, the California Supreme Court has ruled that compelled disclosure of all of the executive's calendar and schedule information would constitute an "intrusion into the deliberative process." (Times Mirror Co. v. Super. Ct. (1991) 53 Cal.3d 1325, 1343.) Consequently the Department is not making public entries that would reveal the Commissioner's deliberative process. (Gov. Code § 6255; Cal. First Amend. Coalition v. Super. Ct. ( 1998) 67 Cal.App.4th 159; Times Mirror Co. ( 1991) 53 Cal.32d 1325.) Further, entries containing certain travel information and information about the Commissioner's security arrangements will not be produced. (Gov. Code§ 6255.) The Department also will not disclose entries that reflect attorney work product or information that is subject to attorney-client privilege. (Gov. Code§ 6254, subds. (b) and (k).)

Similarly, out of consideration for personal privacy concerns, the Department will not disclose personal information about the Commissioner, information related to his personal matters, or information related to his personnel activities, because the Public Records Act also exempts that information from disclosure. For example, the Department will not provide phone numbers or other contact information of either staff or individuals with whom the Commissioner meets, or

CALIFORNIA DEPARTMENT OF INSURANCE PROTECT • PREVENT • PRESERVE Legal Branch-Government Law Bureau 300 Capitol Mall, 17th Floor, Sacramento, CA 9581 4 Tel: (916) 492-3486 * Fax: (916) 324-1883 Email: DebbieLynne. [email protected]. gov Public Records Act Request PRA-2019-00555 Page 2 September 13, 2019

the names of prospective appointees he interviews. (Gov. Code§§ 6254, subd. (c); 6254.3; 6255.)

Please call our Press Office at (916) 492-3566 if you have any questions.

Enclosures

January 7, 2019 Monday

9:00 AM - 10:30 AM Inaugural Ceremony and Celebration of Xavier Becerra Attorney General of the State of California -- California Museum, 1020 O Street, Sacramento, CA

9:00 AM - 10:30 AM Swearing in for Tony Thurmond; Staff: Catalina -- McClatchy High School Main Auditorium, 3066 Freeport Blvd.

10:30 AM - 12:00 PM The Inauguration of Gavin Newsom 40th Governor of California (Seating begins at 10:00am) -- Capitol Building, West Steps of the Capitol, 1013 10th Street

2:00 PM - 3:00 PM Commissioner Ricardo Lara VIP Reception - Reception starts at 2:00pm - Doors open at 1:30pm -- The Bank, 629 J Street, Saramento

2:00 PM - 3:00 PM FYI: Eleni Kounalakis Lieutenant Gov. Inauguration Ceremony -- Tsakopoulos Library Galleria; 828 I Street, Sacramento CA

3:00 PM - 4:30 PM Lara Swearing In -- The Bank, 629 J Street, Saramento

3:30 PM - 4:30 PM FYI: Secretary of State Alex Padilla Swearing-In -- SoS Auditorium, 1500 11th Street

5:00 PM - 8:00 PM EQCA & LGBTQ Caucus Swearing in Celebration -- Badlands Dance Club, 2003 K Street, Sacramento, CA 5‐6pm – VIP Reception 7pm – Program (Speaking – can leave after this)

1

January 8, 2019 Tuesday

9:30 AM - 10:00 AM Swearing In of New Appointees -- 17th Floor Conference Room

1:00 PM - 2:00 PM SAC - Introducing Commissioner Lara -- EDD - 800 Capitol Mall, Sacramento, CA 95814

2:00 PM - 3:00 PM SAC - Tour Facility With Commissioner Lara -- Immediately Following ALL STAFF meeting

5:30 PM - 7:30 PM FYI: Lena Gonzalez Meet & Greet Reception -- Brasserie. 1201 K Street, Sacramento, CA 95814

2

January 9, 2019 Wednesday

11:00 AM - 12:00 PM Meet & Greet with Commissioner Ricardo Lara - San Francisco -- 22nd Floor Hearing Room

12:00 PM - 12:30 PM SF - Tour Facility with Commissioner Lara -- Immediately Following ALL STAFF meeting

5:30 PM - 7:30 PM Latino Caucus Foundation Welcome Back Reception -- Mayahuel, 1200 K Street, Sacramento, CA 95814

6:30 PM - 8:30 PM Attend: SEIU California State Council Farewell for Laphonza Butler, President of SEIU Local 2015 - Ella Dining Room & Bar, 1131 K Street, Sacramento, CA

3

January 10, 2019 Thursday

10:00 AM - 10:30 AM HOLD Meet w/ Catalina and Mike -- CRL's Office

11:00 AM - 12:00 PM Governor's January 10 Budget Release -- SOS Auditorium, 1500 11th St.

3:00 PM - 4:00 PM Continued - Staff Briefing w/ CRL/CHB/MM -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary); SF- 23 Video Conf Rm (Office of Commissioner)

4

January 11, 2019 Friday

9:00 AM - 10:00 AM Breakfast with Ricardo Lara / Dan Weinstein / Fabian Nunez -- Cecconi's 8764 Melrose Ave, Los Angeles, CA 90069

11:00 AM - 12:00 PM Introducing Commissioner Lara -- Ronald Reagan Auditorium, CDI LA, 300 South Spring Street, Sacramento, CA

12:00 PM - 1:00 PM LA - Tour Facility With Commissioner Lara -- Immediately Following ALL STAFF meeting

5

January 12, 2019 Saturday

No responsive calendar entries

6

January 13, 2019 Sunday

No responsive calendar entries

7

January 14-15, 2019 Monday - Tuesday

No responsive calendar entries

8

January 16, 2019 Wednesday

2:30 PM - 3:30 PM Staff Briefing -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); DP Training Room EBHQ Suite 190 - VC Capable

3:30 PM - 4:00 PM Staff Briefing CDI Staff: Catalina, Mike, and Bryant -- Small Conference Room

4:00 PM - 4:30 PM Meeting w/ David & Kristina – CRL's office

4:30 PM - 5:00 PM Staff Briefing w/ COMMS – CRL's Office

9

January 17, 2019 Thursday

11:00 AM - 11:30 AM Scheduling w/ Roberta

12:00 PM - 1:00 PM Confirmed - Staff Briefing; CDI Staff: Catalina, Michael Martinez, Ken, Mike Levy, Geoff -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-14 Video Conf Rm #14001 (Primary)

2:00 PM - 2:20 PM Meet w/ Teachers at Garfield High School -- 5101 E 6th St, Los Angeles, CA 90022

2:30 PM - 3:00 PM Meet w/ Teachers at Stevenson Middle School -- 725 S Indiana St, Los Angeles, CA 90023

10

January 18, 2019 – January 22, 2019 Thursday

No responsive calendar entries

11

January 23, 2019 Wednesday

12:10 PM - 1:30 PM Lunch w/ George Joseph -- Regent Beverly Wilshire, THE Blvd, 9500 Wilshire Blvd, Beverly Hills, CA 90212

12

January 24, 2019 Thursday

10:00 AM - 12:00 PM Commerce Enforcement Tour - Los Angeles / Southern Los Angeles Regional Office --

1:00 PM - 3:00 PM Orange Enforcement Tour - Orange Regional

3:30 PM - 4:30 PM Conference Call/Staff Briefing CDI Staff: Catalina, Mike, Janice, Lan, Simon, Dan & Bruce

13

January 25, 2019 Friday

11:00 AM - 11:30 AM Call w/ President Picker; CDI Staff: Catalina and Mike;

1:23 PM - 1:53 PM Staff Briefing– SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-14 Video Conf Rm #14001 (Primary)

5:00 PM - 6:00 PM Swearing In Ceremony Rehearsal -- James A. Garfield High School, 5101 E 6th St, East Los Angeles, CA 90022 6:00 pm- Friday, January 25th, Event- Swearing In Ceremony Rehearsal Location: James A. Garfield High School, 5101 E 6th St, East Los Angeles, CA 90022

14

January 26, 2019 Saturday

11:00 AM - 2:00 PM Community Swearing In Ceremony for CA Insurance Commissioner Ricardo Lara -- James A. Garfield High School, 5101 E 6th St, East Los Angeles, CA 90022 11:00 am to 2:00 pm, Saturday, January 26th Event: Community Swearing In Ceremony for CA Insurance Commissioner

15

January 27, 2019 Sunday

No responsive calendar entries

16

January 28, 2019 Monday

9:00 AM - 10:00 AM Staff Briefing; SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-11 Video Conf Rm #11300 (COIN)

10:00 AM - 11:00 AM Meeting w/ Catalina -- CRL's office

11:00 AM - 12:00 PM Media Avail to announce the latest wildfire insured loss data and answer reporters’ questions -- CDI Sacramento

12:00 PM - 1:00 PM Telephone Interview

1:30 PM - 2:00 PM Meeting w/ David and Kristina CRL's Office

2:00 PM - 2:30 PM Phone Call w/ NAIC President/ Superintendent Ciopppa

4:00 PM - 5:00 PM Energy Strike Force Meeting -- Governor's Office

5:15 PM - 5:45 PM Meeting w/ Kevin Sloat -- Brasserie. 1201 K Street, Sacramento,

6:15 PM - 7:45 PM Dinner w/ Assemblymember Chad Mayes -- Tiger, 722 K St, Sacramento, CA 95814

17

January 29, 2019 Tuesday

9:00 AM - 1:00 PM Meeting & Media Availbility in Paradise re Workshops; Additional details to Follow -- Paradise Town Hall - Council Chambers or in front of Town Hall, 5555 Skyway Rd., Paradise, CA 95969

9:00 AM - 9:45 AM CRL closed meeting with Paradise officials; CDI Comms Leads: Michael, Byron, Madison -- Paradise Town Hall - Council Chambers or in front of Town Hall, 5555 Skyway Rd., Paradise, CA 95969

3:00 PM - 3:30 PM Meeting w/ Michael Peterson & Geoff -- CRL's Office

4:00 PM - 4:30 PM LIVE INTERVIEW w/ Steve Jaxon, KSRO Radio

6:45 PM - 8:15 PM Dinner w/ Senator Holly Mitchell - Andy Nguyen's Vegetarian Restaurant, 2007 Broadway, Sacramento, CA 95818

18

January 30, 2019 Wednesday

1:00 PM - 2:00 PM Meet & Greet w/ Nationwide's Head of their State Legal Team, Jayme Smoot, re discuss opportunities to work with CDI

2:00 PM - 3:00 PM Staff Briefing CDI Staff: CRL, Catalina, Michael, George, Jack, Eric and Jan; LA-14 Video Conf Rm #14001 (Primary); SAC-17 Video Conf Rm #17005 (Primary)

3:00 PM - 3:30 PM Dropping by to say hello to Accreditation Team -- 13th

4:00 PM - 5:00 PM Meeting w/ Eric Serna re regarding Short Term Medical and also a meet and greet with Commissioner Lara -- LA-14 Conf Rm #14330 (Actuarial)

6:30 PM - 7:15 PM Attend: Special Evening w/ Planned Parenthood Federation of America President & CEO Dr. Leana Wen & Planned Parenthood Los Angeles,

19

January 31, 2019 Thursday

10:00 AM - 10:30 AM Conference Call; CDI Staff: Catalina, Mike M, Mike P.

11:30 AM - 12:45 PM CONF Lunch w/ Dennis Gilbert, Dan Weitzman & Dan Weinstein -- Wolfgang Puck for lunch in LA Live – 800 W Olympic Blvd., Los Angeles, CA 90015

6:00 PM - 8:30 PM Confirmed Attend USC Sol Price School of Public Policy 90th Anniversary Celebration -- Los Angeles City Hall

20

February 1, 2019 Friday

12:00 AM - 12:00 AM Commissioners Conference (Feb 1-4) -- La Quinta A Waldorf Astoria Hotel, LaQuinta, CA

8:00 AM - 6:00 PM NAIC 2019 Commissioners' Conference -- La Quinta, CA

10:45 AM - 11:15 AM Staff Briefing -- Meet in Lobby Restaurant

12:00 PM - 2:00 PM Speak /Attend Golden Gate Business Association's Power Lunch NOTE: CRL to speak for 5-10 min -- San Francisco Marriott Marquis, 780 Mission Street, San Francisco, CA 94103

4:45 PM - 5:30 PM FYI: NAIC Commissioner Mentoring Program Reception -- President Cioppa Hotel

5:30 PM - 8:30 PM FYI: Conference Welcome Reception and Dinner -- La Quinta—La Casa Complex

21

February 2, 2019 Saturday

All Day Commissioners Conference (Feb 1-4) -- La Quinta A Waldorf Astoria Hotel, LaQuinta, CA

7:00 AM - 8:20 AM Breakfast - All Members/Commissioners -- Flores Ballroom 4 7:00 a.m. – 8:20 a.m. Breakfast—Flores Ballroom 4

8:20 AM - 8:30 AM NAIC President’s Welcome and Opening Remarks - Superintendent Eric A. Cioppa (ME), NAIC President -- Flores Ballrooms 5-8

8:30 AM - 9:30 AM “DC Landscape for 2019”, Mike Consedine, NAIC CEO, Ethan Sonnichsen, NAIC Managing Director, Gov’t Affairs -- Flores Ballrooms 5-8

9:30 AM - 10:15 AM Health Insurance Issues Brian Webb, NAIC Asst. Director, Life & Health Policy Legislation -- Flores Ballrooms 5-8

10:15 AM - 10:30 AM Break

10:30 AM - 12:00 PM Breakout Session: Discuss NAIC 2019 Key Initiatives Superintendent Eric A. Cioppa (ME), NAIC President -- Flores Ballrooms 5-8

11:00 AM - 11:45 AM NAIC Legal Issues & Corporate Matters, Kay Noonan, NAIC General Counsel -- Flores Ballrooms 5-8

1:30 PM - 3:00 PM Member Discussion of Key Initiatives: Long-Term Care Insurance Issues. TBD, Flood Insurance Education Program Laura Kane, NAIC Communications Director -- Flores Ballrooms 5-8

3:15 PM - 4:30 PM NAIC Zone Meetings - Western Zone -- Western Zone – Flores Ballroom 3

6:15 PM - 9:30 PM Commissioners Reception & Dinner - (Buses depart La Quinta at 5:45 p.m.) -- The Living Desert

22

February 3, 2019 Saturday

All Day Commissioners Conference (Feb 1-4) -- La Quinta A Waldorf Astoria Hotel, LaQuinta, CA

7:15 AM - 8:30 AM Breakfast -- Adobe Grill 7:15 a.m. – 8:30 a.m. Breakfast—Adobe Grill

8:30 AM - 9:30 AM NAIC Officer Special Election Superintendent Eric A. Cioppa (ME), NAIC President -- Flores Ballrooms 5-8

9:30 AM - 10:15 AM Commissioner Training: The NAIC Standing Committee Process Superintendent Eric A. Cioppa (ME), NAIC President -- Flores Ballrooms 5-8

10:15 AM - 10:30 AM Break

10:30 AM - 12:00 PM Member Discussion of Key Initiatives: Cybersecurity / Data Privacy TBD Best Interest Standard TBD -- Flores Ballrooms 5-8

23

February 4, 2019 Monday

12:00 AM - 12:00 AM Commissioners Conference (Feb 1-4) -- La Quinta A Waldorf Astoria Hotel, LaQuinta, CA

12:45 PM - 1:00 PM Staff Briefing; CDI Staff: Catalina, Mike M, and Mike P -- CRL's office

1:00 PM - 1:45 PM Meeting w/ Ryan Brooks, Brooks Consulting, Tim Simon (former CPUC Commissioner), Christopher F. Guth, Attestor Capital Fund re Insurance Issues related to the PG & E fires; CDI Staff: CRL, Catalina, Michael M, Mike P and Joel -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

1:00 PM - 1:30 PM Meeting w/ Sharon -- CRL's office

2:30 PM - 3:00 PM Meeting w/ David & Roberta re Scheduling -- CRL's office

3:00 PM - 4:00 PM Staff Briefing Staff: CRL, Catalina & Mike L. -- SAC-17 Video Conf Rm #17005 (Primary)

4:15 PM - 4:45 PM Meeting w/ Steve Clark, Vice President of Insurance Services Office (ISO) and Kara Cross -- SAC-17 Video Conf Rm #17005 (Primary)

24

February 5, 2019 Tuesday

9:15 AM - 10:00 AM CONFIRMED - Meeting w/ Auto Alliance Members John Moffat and Curt Augustine re Crash Parts; CDI Staff: Catalina, Michael and Tony -- SAC-17 Video Conf Rm #17005 (Primary)

12:30 PM - 1:00 PM Staff Briefing re Climate Branch UpdateCDI Staff: Mike, Mike and Joel -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

1:00 PM - 2:00 PM Office Work Time

7:30 PM - 8:30 PM Late Dinner w/ Senator Durazo – Beast + Bounty, 1701 R Street, Sacramento, CA 95811

25

February 6, 2019 Wednesday

9:00 AM - 9:45 AM Meeting w/ Senator Hannah Beth Jackson re Insurance Costs in Fire Hazard Areas; CDI Staff: FYI: Catalina, Michael M and Mike P attending w/ CRL -- State Capitol, Rm 2032

10:30 AM - 11:30 AM Meeting w/ Laurie; CDI Staff: Catalina, Mike, Julia and Laurie -- SAC-17 Video Conf Rm #17005 (Primary)

11:30 AM - 12:15 PM Confirmed Meeting w/ Germaine "Gerrie" Marks, Vice President - Governmental Affairs w/ Prudential Financial (also, Former Director and Deputy Director of the Arizona Department of Insurance) -- SAC-17 Video Conf Rm #17005 (Primary)

2:00 PM - 3:00 PM CONFIRMED - Provide Opening Remarks at Capitol Insurance Legislative Briefing; "Homeowners Insurance: Briefing on District Educational Opportunities" - State Capitol, Room 2040

3:30 PM - 4:15 PM Staff Briefing CDI Staff: Catalina, Ken, Susan, Bryant, Geoff, Pat, and Brentley -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

4:15 PM - 4:45 PM Staff Briefing CDI Staff: CRL, Catalina, Michael, Janice & Tony -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary)

5:30 PM - 6:30 PM Speak be recognized at the NALEO Reception in Honor of CA's Five Latino State Constitutional Officers; California Museum, 1020 O Street, Sacramento

26

February 7, 2019 Thursday

9:30 AM - 10:00 AM Meeting w/ Pedro Pizarro, President of Edison re Wildfire Commissioner, CDI Staff: Catalina, Michael and Mike P -- SAC-17 Video Conf Rm #17005 (Primary)

10:00 AM - 10:30 AM Prepare CRL Video for Swearing in/Promotion of four CDI enforcement officers in Fresno -- CRL's Office

12:00 PM - 1:00 PM ACLHIC will be hosting a lunch in support of the LGBT Foundation -- Brasserie Capitale – 1201 K Street, #100, Sacramento, CA

27

February 8, 2019 Friday

No responsive calendar entries

28

February 9, 2019 Saturday

No responsive calendar entries

29

February 10, 2019 Sunday

No responsive calendar entries

30

February 11, 2019 Monday

All Day FYI: Reception for MX Ambassador Liliana Ferrer Upon Adjournment Of Session -- Willie Brown Jr. -- Conference Room, State Capitol

9:00 AM - 10:00 AM Meeting w/ State Farm Mutual' s Senior Vice President, Tom Conley and Paul Smith, Executive Vice President of Property and Casualty; CDI Staff: Catalina, Mike, Joel & Ken Schnoll -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

10:00 AM - 11:00 AM Office Work Time

12:15 PM - 1:00 PM Staff Briefing; CDI Staff: Catalina, Michael, Bryant, Pat and Brentley -- SAC-17 Video Conf Rm #17005 (Primary); SF-21 Video Conf Rm #21010 (Primary)

1:00 PM - 2:00 PM Staff Briefing CDI Staff: Catalina, Michael, Geoff and Ken -- SAC- 17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

2:00 PM - 2:30 PM Staff Briefing w/ Mike P CDI Staff: Mike -- CRL's Office

3:00 PM - 3:30 PM Rescheduled Staff Environment Meeting + Facilities Presentation w/ Julia, Laurie & Richard -- SAC-17 Video Conf Rm #17005 (Primary)

6:00 PM - 8:00 PM Reception + Dinner for His Excellency the President of the Regional Government of the Azores, Vasco Cordeiro, along with an official delegation of the Regional Government of the Azores -- The Sutter Club, 1220 9thStreet, Sacramento, CA; Note; Business Attire

31

February 12, 2019 Tuesday

8:00 AM - 9:00 AM FYI: Latino Caucus Meeting -- 1029 J Street, 3rd Floor Conference Room

10:15 AM - 12:15 PM State of the State -- State Capitol

12:15 PM - 1:00 PM Staff Briefing CDI Staff: Catalina, Michael M, Tony, Joel, Michael L., Ken, Ken, Melissa and Melerie -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-14 Video Conf Rm #14001 (Primary)

1:00 PM - 1:30 PM Staff Briefing; CRL's Office

2:00 PM - 2:30 PM Meeting w/ David & Roberta re scheduling items -- CRL's office

5:00 PM - 6:30 PM CIRF Reception Hosted by Senate President pro Tempore Toni Atkins -- State Capitol - Room 211

5:30 PM - 7:30 PM Attend: Barona Band of Mission Indians Reception -- The Grand, 1600 L Street, Sacramento, CA

7:00 PM - 8:00 PM Drop by Dinner in Delegation's Honor Japan led by Member of the National Parliament, Iwao Horii -- Esquire Grill Restaurant, 1213 K St, Sacramento, CA 95814

32

February 13, 2019 Wednesday

9:30 AM - 10:00 AM Staff Briefing -- CRL's Office

10:30 AM - 11:00 AM Interview w/ Emily C. Dooley w/ Bloomberg Environment re California Disaster Insurance Bill; CDI Staff: Michael; Contact: Emily

11:00 AM - 11:30 AM Phone Interview w/ Don Jergler, Insurance Journal re California Disaster Insurance Bill; CDI Staff: Michael S; Contact: Don

12:15 PM - 12:45 PM Meeting w/ Kent Kauss, VP of Sempra Energy, Karen Sedwick, Treasurer of Sempra, Paul Bauer, Partner at Mercury Public Affairs and Laura Parra Senior VP at Mercury Public Affairs; CDI Staff: Catalina, Michael M and Mike P -- SAC-17 Video Conf Rm #17005 (Primary)

4:45 PM - 5:15 PM Phone Interview w/ Colby Bermel, Energy Reporter, POLITICO, CA; CDI Staff: Michael S; Contact Colby

5:00 PM - 7:30 PM Attend: Dave Low's Retirement Reception -- California Democratic Party Headquarters, 1830 9th Street, Sacramento, CA 95811

33

February 14, 2019 Thursday

11:00 AM - 11:50 AM Press Conference - California Disaster Insurance w/ CRL, Senator Bill Dodd & Treasurer Fiona Ma -- Governor’s Press Room, State Capitol Room 1190

12:00 PM - 1:00 PM CONFIRMED Meeting w/ Santa Rosa Mayor, Santa Rosa City Manager and County Supervisors Gore & Gossman; CDI Staff: Catalina, Michael, Joel and Tony -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

34

February 15, 2019 Friday

11:00 AM - 11:30 AM Meeting w/ Karl D. Susman; re potential solution to the insurance crisis we are experiencing in California due to the wildfires; CDI Staff: Catalina, Michael, Julia, Tony and Joel; Adding SF location for Joel -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

12:30 PM - 2:00 PM Lunch w/ SOS Alex Padilla; Contact: Carmen -- 601 So. Central Ave., Los Angeles

3:00 PM - 3:30 PM Conference Call w/ CEO Jim Mangia, St. John's Well Child and Family Center to discuss health policies going into 2019; CDI Staff: Tony; FYI: Catalina and Janice (if you are able to call in)

6:00 PM - 8:00 PM First Speaker/Opening Remarks "Welcome to California" & to HRC's 6th Annual Time to THRIVE Conference; CONTACT: Hope Anaheim Marriott, 700 West Convention Way, Anahein, California 92802 Attendees are primarily made of K-12 educators, counselors, social workers, after-school program staff, etc from all 50 states.

35

February 16, 2019 Saturday

No responsive calendar entries

36

February 17, 2019 Sunday

No responsive calendar entries

37

February 18, 2019 Monday

All Day Presidents' Day Holiday

No responsive calendar entries

38

February 19, 2019 Tuesday

9:00 AM - 10:00 AM Coffee and roundtable discussion -- California Fresh Fruit Association, 7647 N. Fresno St., Fresno, CA 93720

11:00 AM - 1:15 PM Attend Swearing - In Ceremony for Captain and Sergeants + Fresno Office Tour -- Central Valley Regional Office (Fresno)

1:00 PM - 1:15 PM Interview (Taped/Standup) w/ Liz Gonzales of KMPH-TV (Fox), re Discuss Wildfire Insurance Plan for California -- Fresno Enforcement Office

1:30 PM - 2:00 PM Meeting with Ed Kashian and Sal Gonzales; Contact: -- Kashian Enterprises, 265 E. River Park, Suite 150, Fresno, CA 93720

2:20 PM - 2:50 PM Interview (TV/Taped) w/ Evan Onstot w/ KSEE24 Studio re Discuss Wildfire Insurance Plan for California -- Studio is located at 5035 E. McKinley Ave. in Fresno near the airport

39

February 20, 2019 Wednesday

10:30 AM - 11:00 AM Interview (Telephone) w/ Melanie Mason w/LA Times; re reasons for introducing the bill, etc. -- Call Melanie

10:30 AM - 11:00 AM Staff Briefing w/ Michael

11:10 AM - 11:40 AM Review Legal Emails -- CRL's

12:00 PM - 1:30 PM Attend: USC President Wanda M. Austin –

2:30 PM - 3:00 PM Meeting w/ Senator Hueso -- CRL's office

3:00 PM - 3:30 PM Meet w/ Roberta and David -- CRL's Office

3:30 PM - 4:15 PM Staff Briefing; CDI Staff: Catalina (FYI), Michael, Ken and Tony -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-14 Video Conf Rm #14001 (Primary)

6:00 PM - 7:30 PM Stop By EQCA Sacramento Kickoff Reception for Mandy Lee and Joe Gregorich -- Amanda and Paul Bauer Home

6:00 PM - 7:00 PM Confirmed Dinner w/ Asm Daly -- TableVine: 1501 14th St, Sacramento, CA 95814

40

February 21, 2019 Thursday

9:15 AM - 9:45 AM In person Interview w/ Muna Sadek, CTNS re Preview of Chico wildfire survivor workshop -- CDI in the small conference room next to his office on 17

10:00 AM - 10:30 AM Staff Briefing; CDI Staff: Catalina, Michael and Mike Peterson -- CRL's office

10:45 AM - 11:15 AM CRL to Present Retirement Certificate -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

41

February 22, 2019 Friday

10:00 AM - 10:45 AM Staff Briefing re Chico Townhall; CDI Staff: Catalina, Michael M., Tony, Michael, Byron, Julia, George (optional), Kathleen & Amorette; SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

42

February 23, 2019 Saturday

9:00 AM - 2:30 PM Camp Fire/Chico Townhall -- Townhall at Laxson Auditorium, Chico State, 400 West First St, Chico CA 95929

10:30 AM - 11:00 AM Commissioner Lara Visits with Survivors

43

February 24, 2019 Sunday

No responsive calendar entries

44

February 25, 2019 Monday

9:15 AM - 9:45 AM Call w/ Supt. Cioppa & Andy Beal re Letter sent to Supt. Cioppa

45

February 26, 2019 Tuesday

4:00 PM - 7:30 PM Speak at Somos Un Pueblo Unidos Immigrant Justice in a New Era; speak re Immigrant Rights; Governor Grisham speaking as well; -- La Fonda Hotel on the Plaza, 100 E San Francisco St , Santa Fe, NM 87501

46

February 27, 2019 Wednesday

8:00 AM - 11:00 AM SPEAK on Panel - New Mexico Superintendent Office of Insurance hosting a panel sponsored by GoHealth re: Wildfires and Homeowners Coverage Impacts & Automobile Issues: Ride Sharing & Automated Vehicles -- Drury Plaza Hotel Santa Fe; 828 Paseo de Peralta, Santa Fe, NM 87501

47

February 28, 2019 Thursday

10:30 AM - 11:00 AM Meeting w/ Catalina -- CRL's office

11:30 AM - 12:00 PM Meeting w/ Roger Grenier (AIR) and Kara Cross -- SAC-17 Video Conf Rm #17005 (Primary)

12:15 PM - 12:45 PM Meeting w/ Richard Jones, VP, State Affairs, Guardian Life Insurance Company of American; CDI Staff: Catalina, Michael and Janice -- SAC-17 Video Conf Rm #17005 (Primary)

12:45 PM - 1:30 PM Staff Briefing -- SAC-17 Video Conf Rm #17005 (Primary); LA-9 Video Conf Rm #9001 (Secondary)

48

March 1, 2019 Thursday

11:30 AM - 1:00 PM Lunch w/ Nick Roxborough; Contact: Lucy -- Otium, 222 South Hope Street, Los Angeles, CA 90012

1:30 PM - 2:00 PM Meeting w/ the FAIR Plan, Anneliese Jivan, President of California Fair Plan; FYI ONLY for CDI Staff -- CRL's LA Office

2:15 PM - 3:00 PM Staff Briefing re Malibu/ Thousand Oaks Town Hall - -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-14 Video Conf Rm #14001 (Primary)

3:00 PM - 3:30 PM Record a short video for social media with CRL discussing the California Earned Income Tax Credit (CalEITC) -- CRL's LA Office

49

March 2, 2019 Saturday

All Day Media Availability: Before event, in between visiting with survivors, and other times convenient to Commissioner and working with Communications

8:45 AM - 9:30 AM Tour of Burn Area -- Agoura Hills

9:45 AM - 10:00 AM Commissioner Lara returns to Townhall Venue - CDI Staff Briefing

10:00 AM - 2:30 PM Malibu/ Thousand Oaks Town Hall -- Conrad N. Hilton Foundation, 30440 Agoura Road Agoura Hills CA 91301

10:00 AM - 10:20 AM Commissioner Lara Kicks off Workshop - Provides Intro Remarks

10:20 AM - 11:00 AM (10:20-11:00am): TBD; possible informal meetings with officials, or media interviews, or meeting with CDI staff and Insurers prior to appointments starting at 11am.

11:00 AM - 1:00 PM Commissioner Lara Visits with Survivors

50

March 3, 2019 Sunday

No responsive calendar entries

51

March 4, 2019 Monday

1:00 PM - 1:30 PM Phone call w/ Catalina and Michael

2:30 PM - 3:00 PM Call w/ Mitch Steiger (WCIRB Governing Committee)

3:00 PM - 3:30 PM Call

52

March 5, 2019 Tuesday

8:15 AM - 9:00 AM Meet w/ Bob Nadeau and Mr. David Maurstad Associate Administrator for FEMA -- 500 C St. SW, Washington D.C. 20472

9:00 AM - 10:00 AM Lunch w/ Congressman Jimmy Gomez (Reservation under Gomez); FYI Only for Mike P -- Democratic Club - 30 Ivy St SE, Washington, DC 20003

10:20 AM - 11:50 AM Updated location Meeting w/ World Bank's Olivier Mahul w/ Mike Peterson -1:00 - 2:30pm Eastern; -- 2121 Pennsylvania Ave NW., Washington, D.C.

12:00 PM - 1:00 PM Meeting with Messrs. Ricardo Lara / Mike (Insurance Commissioner & Deputy Commissioner on Climate and Sustainability, CA) 3:00 - 4:00pm -- Mr. Srinivasan's Office - IMF Building: HQ1-10-382, 700 19th St NW, Washington, DC

1:30 PM - 2:00 PM Meet and Greet w/ Jennifer Ludden, NPR; re climate agenda w/ Mike P staffing -- NPR, 1111 North Capitol St NE, Washington, DC 20002

53

March 6, 2019 Wednesday

6:00 AM - 9:00 AM NALEO Board of Directors meeting; 9-Noon -- Marriott Marquis, 901 MASSACHUSETTS AVE NW, WASHINGTON, DC 20001

9:00 AM - 9:30 AM Meet and Greet w/ Scott Wilson, Washington Post re Background meeting on climate agenda; CDI Staff: Mike; -- MARRIOTT MARQUIS WASHINGTON, 901 MASSACHUSETTS AVE NW, WASHINGTON, DC 20001, USA

9:30 AM - 10:00 AM Meet and Greet w/ Chris Flavelle, Bloomberg; re Background meeting on climate agenda; CDI Staff: Mike P; Meet in Hotel Lobby - - MARRIOTT MARQUIS WASHINGTON, 901 MASSACHUSETTS AVE NW, WASHINGTON, DC 20001, USA

11:00 AM - 11:30 AM Meeting w/ Robert Edmonson, Chief of Staff for Speaker Nancy Pelosi -- 1236 Longworth HOB 12:00 PM - 12:30 PM Confirmed Meeting w/ Armand Feliciano (GEICO), Hank (General Counsel), Richard, (VP, Legislative Counsel, and possibly Chief Legal Officer -- Lobby of the Marriott Marquis, located at 901 Massachusetts Ave. NW, Washington, DC

2:30 PM - 5:30 PM Attend: Edward R. Roybal Legacy Gala; Note this is not the day you are being honored - that is 3/9/19 -- Marriott Marquis - Marquis Ballroom, Meeting Level 2 - 901 Massachusetts Avenue NW, Washington, D.C. 20001

54 March 7, 2019 Thursday

11:00 AM - 11:30 AM Call w/ Sharon

55

March 8, 2019 Friday

10:00 AM - 11:30 AM 2019 Industry Fiscal Briefing -- CDI, 300 Capitol Mall, 13th floor, Sacramento, CA

56

March 9, 2019 Saturday

6:00 PM - 11:00 PM Attend/Accept: Edward R. Roybal Public Service Award at our 59th Annual Installation & Awards Gala from the Mexican American Bar Association of Los Angeles County; Note: Julia will be staffing you -- Millennium Biltmore Hotel, 506 S. Grand Ave., Los Angeles, CA

57

March 10, 2019 Sunday

11:00 AM - 12:30 PM Speak at ROAR Meeting re CRL's Responsibilities & Plans as State Insurance Commissioner and Insights on the most import issues facing California over the next two years; Contact: Michael The Chapel at Abbey Bar and Restaurant, 692 N Robertson Blvd West Hollywood

7:30 PM - 9:00 PM Dinner w/ SDSU/Imperial Valley Students in town for the CHESS Advocacy Conference -- Lucca Restaurant and Bar, 1615 J Street, Sacramento, CA

58

March 11, 2019 Monday

9:30 AM - 10:00 AM Staff Briefing CDI Staff: Catalina, Michael, Camille, Natalie, Ken Allen -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary)

10:05 AM - 10:15 AM Board and Committee Interview -- CRL's office

10:30 AM - 10:40 AM Board and Committee Interview -- CRL's office

10:40 AM - 10:50 AM Board and Committee Interview -- CRL's Sacramento Office

11:30 AM - 12:00 PM Meeting with Mike P -- CRL’s office

1:00 PM - 2:00 PM Confirmed Meeting w/ Consumer Attorneys of California re General Legislation; CDI Staff: CRL, Catalina and Mike -- SAC-17 Video Conf Rm #17005 (Primary)

2:00 PM - 2:30 PM Meeting w/ David and Roberta -- CRL's office

3:00 PM - 3:30 PM Staff Briefing -- SAC-17 Video Conf Rm #17005 (Primary)

3:30 PM - 4:15 PM DMHC Director Rouillard & DMHC Chief Deputy Director Marta Green re Health Care Access & Shared Goals; CDI Staff: Catalina, Michael & Janice -- SAC-17 Video Conf Rm #17005 (Primary)

6:30 PM - 7:30 PM Dinner w/ Senator Herzberg -- Zocalo, 1801 Capitol Ave, Sacramento, CA 95811

59

March 12, 2019 Tuesday

9:00 AM - 9:30 AM Opening Keynote Speaker at the American Property Casualty Insurers of America Legislative Action Day; re Commissioner's agenda. New things at the Department. Issues facing the insurance industry -- California Chamber of Commerce, 1215 K Street, 14th Floor, Sacramento - Contact Mark Sektnan - Michael M will staff you at this event

11:30 AM - 12:30 PM Meet & Greet - Lunch with Berkshire Hathaway -- Camden, Spit & Larder: 55 Capitol Mall #100, Sacramento, CA 95814

5:00 PM - 6:00 PM Dinner w/ Henry Perea; Contact: Zorka -- Ella Dining Room located at 1131 K St

60

March 13, 2019 Wednesday

10:00 AM - 10:30 AM CRL join the Governor at the State Capitol to announce Criminal Justice – Pro Tem's Office

11:30 AM - 12:00 PM Meeting w/ Catalina -- CRL's

1:00 PM - 2:30 PM March Board Briefing w/ CEA Meeting w/ Glenn Pomeroy, CEO, California Earthquake Authority -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

61

March 14, 2019 Thursday

10:00 AM - 10:10 AM Board and Committee Interview -- CRL's LA Office

10:15 AM - 10:25 AM Board and Committee Interview -- CRL's LA Office

10:30 AM - 10:40 AM Board and Committee Interview -- CRL's LA Office

11:00 AM - 11:30 AM Meeting w/ Angela re LA Office -- CRL's LA Office

11:30 AM - 12:00 PM Picture w/ Accreditation Team for NAIC -- Building Lobby by the fountain

1:00 PM - 4:00 PM Confirmed Large Group/RX Public Meeting -- LA Hearing Room

7:00 PM - 9:00 PM CA Legislative LGBTQ Caucus Dinner w/ Special Guest Michael Fleming, Executive Director of the David Bohnett Foundation; Contact: Alina -- Lucca Restaurant and Bar, 1615 J Street, Sacramento, CA

62

March 15, 2019 Friday

10:45 AM - 11:15 AM Staff Briefing; CDI Staff: Catalina, Michael, Geoff, Ken S., Ken A., Joel, Byron and Mike S -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-14 Video Conf Rm #14001 (Primary

12:30 PM - 1:00 PM SPEAK at LGBTQ Leadership Summit/ Equality CA Event; re on importance of LGBTQ representation, the significance of being the first openly-LGBTQ person elected to statewide constitutional office, lessons learned -- Kimpton Sawyer Hotel, Magnolia Room (500 J St., Sacramento)

1:30 PM - 2:15 PM Meeting w/ Bruce Byrne, Berkshire Hathaway Direct and John Finston, Drinker Biddle & Reath, LLP re New small commercial product; CDI Staff: Catalina, Michael, Ken, Ken and Pat -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-14 Video Conf Rm #14001 (Primary)

2:15 PM - 2:30 PM NAIC's April meeting update -- CRL's office

63

March 16, 2019 Saturday

No responsive calendar entries

64

March 17, 2019 Sunday

No responsive calendar entries

65

March 18, 2019 Monday

1:30 PM - 2:15 PM Meeting w/ Carmen Balber, Executive Director and Pam Pressley, Senior Staff Attorney w/ Consumer Watchdog; Staff: Catalina and Michael -- 6330 San Vicente Blvd, Ste. 250, Los Angeles, CA 90048

66

March 19, 2019 Tuesday

8:30 AM - 9:30 AM Speak at Los Angeles Latino Chamber of Commerce (LALCC) Distinguished Speaker Series; per discussion with Maribel; Contact: Maribel Serrano -- California Club, 538 Flower Street, Downtown LA

4:30 PM - 6:00 PM FYI: State of the Judiciary Reception -- Stanley Mosk Library and Courts Building, 914 Capitol Mall, Sacramento

8:15 PM - 9:45 PM Dinner w/ Assemblymember Limon & Nathalie Reyes from Group Salinas; Contact: Laura Parra -- Moxies located at 2028 H St, Sacramento, CA 95811

67

March 20, 2019 Wednesday

9:00 AM - 9:30 AM Speak – CRL speaking at the California Cannabis Industry Association Conference (CCIA) Policy Conference; The Sheraton Grand Hotel, 1230 J Street, Sacramento, CA - NOTE: Camille will staff CRL

10:45 AM - 11:30 AM Interview (in person/studio) w/ Jairo Diaz, Univision Sacramento- 19 Conexion re CDI priorities and CRL election as first LGBTQ statewide leader; Michael S to staff CRL -- Univision Channel 19, 1710 Arden Way, Sacramento, CA 95815

12:00 PM - 12:30 PM Meeting w/ Peter Lee, Covered CA -- SAC-17 Video Conf Rm #17005 (Primary)

5:00 PM - 8:00 PM Honored at Equality Trailblazer Award at the Sacramento Equality Awards (award presented by the Pro Tem at approx. 7:00pm) Staff: Michael M; Contact Mario -- The Golden 1 Center, 500 David J Stern Walk Staffing: Michael

68

March 21, 2019 Thursday

10:15 AM - 11:30 AM Speak (Keynote) at California Workers’ Compensation Institute (CWCI) at their Annual Meeting; Theme is "Changing Tides"; Note: Joel (Primary) and Pat Hein to staff CRL -- Marriott Oakland City Center, 1001 Broadway, Oakland, CA

11:30 AM - 12:00 PM Meeting w/ Vern Steiner, State Fund CEO & Jennifer Vargen, Executive Vice President of Public Affairs; "Meet and Greet"; CDI Staff: Joel & Pat; Contact Hilda / Day of Event Contact: Perla -- Oakland City Center Marriott (California Room, 3rd floor)

12:15 PM - 12:45 PM Conference Call w/ Catalina, Michael and Bryant --

1:30 PM - 2:00 PM Staff Briefing

3:30 PM - 4:15 PM Meeting w/ Malia Cohen -- San Francisco, CA

7:00 PM - 8:30 PM Keynote (Speak around 7:30pm) Eden Area United Democratic St. Patrick's Day Dinner Event; Contact: Robin Torello -- Carpenters Union Hall, Local 713, at 1050 Mattox Road in Hayward

69

March 22, 2019 Friday

No responsive calendar entries

70

March 23, 2019 Saturday

6:30 PM - 10:00 PM Drop By: California Federation of Teachers Anniversary Gala – Millenium Biltmore Hotel, 506 S. Grand Avenue, Los Angeles, CA

8:15 PM - 9:15 PM Speak at St. John's Well Child & Family Center Annual Gala; Contact: Mario; Staff: Julia -- Los Angeles’ Historic Union Station, 800 N Alameda St, Los Angeles, CA 90012

71

March 24, 2019 Sunday

No responsive calendar entries

72

March 25, 2019 Monday

No responsive calendar entries

73

March 26, 2019 Tuesday

7:00 AM - 8:00 AM Meet w/ David Robinson, Chris Swift and Meggan Conner & Tour the Office of The Hartford; Contact: Meggan

9:50 AM - 11:00 AM Lunch with Dr. Michael Mendez, Yale faculty, and queer climate experts -- Harvest Restaurant, 1104 Chapel Street (Michael will pick you up in the hotel lobby)

11:30 AM - 1:00 PM Campus tour (weather permitting) through Old Yale Campus to the School of Forestry (1 mile walk)

1:30 PM - 3:30 PM Speak on Panel re "Queer and Present Danger in the Age of Climate Change);; Contact: Michael Anthony Mendez -- Yale School of Forestry & Enviro Studies, 195 Prospect Street, Sage Hall, Bower Auditorium, New Haven, CT

4:30 PM - 6:00 PM Dinner with Dr. Michael Mendez -- Barcelona Restaurant, 155 Temple Street.

74

March 27, 2019 Wednesday

No responsive calendar entries

75

March 28, 2019 Thursday

9:30 AM - 10:00 AM Studio Interview w/ L.A. host Alyssa Julya Smith, Cheddar re SB 568 (Prime Time Primary law) and its impact on California in 2020; Contact: Taylor Fleming, booking producer, - ONSITE CHEDDAR CONTACT: Rory Bryant -- Cheddar studio, 1601 Vine Street, Los Angeles, CA; NOTE: Byron staffing CRL

1:30 PM - 2:00 PM Conference Call/ Staff Briefing

2:20 PM - 4:30 PM LGBT caucus/WSPA Discussion of Oil & Gas in California, Led by Shant Apekian, WSPA -- The US Grant, 326 Broadway, San Diego, CA 92101

5:00 PM - 5:45 PM Meeting w/ Mitch Mitchell (Sempra) and Greg Campbell; Contact: Danielle Executive Assistant, Eugene “Mitch” Mitchell, VP-State Gvt Affairs & Ext Affairs -- US Grant Hotel 326 Broadway, San Diego, CA 92101 (Lobby)

76

March 29, 2019 Friday

12:00 PM - 12:45 PM NAIC Officers, CEO, COO and Trish Schoettger Short Conference Call

77

March 30, 2019 – March 31, 2019 Saturday - Sunday

No responsive calendar entries

78

April 1, 2019 Monday

9:30 AM - 10:30 AM Speak at City of Palm Springs, Palm Springs Pride re The legacy of Cesar Chavez; Contact: Ron deHarte -- Sunrise Pavilion, 401 S. Pavilion Way, Palm Springs, CA 92262

79

April 2, 2019 Tuesday

9:30 AM - 10:30 AM CONFIRMED - Distracted Driving Press Conference w/ Auto Club of Southern California AAA; Morning of April 2nd -- Gilbert Lindsay Plaza – adjacent to LA Convention Center and Staples Center on west side of Figueroa between Pico and 12th

11:00 AM - 12:00 PM CONFIRMED Tour + Meeting w/ Auto Club (AAA) CEO and others after Press event in Downtown LA -- Automobile Club of Southern California’s historic Los Angeles Headquarters – 2601 South Figueroa Street, Los Angeles, CA 90007

1:00 PM - 1:30 PM Meet and greet with Robert Barbarowicz of Michelman & Robinson and representatives of Lloyd's of London -- DTLA CRL Executive Office

1:30 PM - 2:00 PM Meet and Greet with Chubb's General Counsel, Kevin Rampe and Manolo Morales, Vice President & Counsel of State Government and Industry Affairs and several senior executives from the East Coast -- DTLA CRL Executive Office

2:00 PM - 2:30 PM Staff Briefing CDI Staff: Catalina and Michael

6:00 PM - 7:00 PM Dinner w/ Dr. Robert Hertzka; Note: Reservation under Lara for "2" -- Camden Spit & Larder, 555 Capitol Mall, Ste. 100, Sacramento, CA 95814

80

April 3, 2019 Wednesday

9:30 AM - 10:00 AM Testify on CDI-sponsored bill at Assembly Insurance Committee Hearing; -- State Capitol Room 437

10:00 AM - 11:00 AM Attend Senate Insurance Committee informational hearing on "Overview of Insurance and Insurance Regulation" -- State Capitol, Room 113

11:30 AM - 12:00 PM Staff Briefing -- SAC-17 Video Conf Rm #17005 (Primary); LA-9 Video Conf Rm #9001 (Secondary)

1:00 PM - 1:20 PM COIN Advisory Board Meeting - SAC 16

81

April 4, 2019 Thursday

No responsive calendar entries

82

April 5, 2019 Friday

7:00 AM - 9:00 AM HOLD for Potential Additional Meetings at NAIC -- Cordova 2

10:00 AM - 10:30 AM HOLD for Potential Additional Meetings at NAIC -- Cordova 2 JW Marriott – Lower Level

11:00 AM - 2:00 PM Financial Regulation Standards and Accreditation (F) Committee (Regulator Only) - Voting on Accreditation likely done by 2:30pm -- Coquina Ballroom North - JW Marriott - Lobby Level

1:00 PM - 2:00 PM FYI: (optional) In-person NAIC New Commissioner National Meeting Briefing -- Mediterranean Ballroom Salon 3 - JW Marriott - Lobby Level

3:00 PM - 5:00 PM Commissioner's Meet and Greet -- Cordova 2 - JW Marriott - Lower Level

83 April 6, 2019 Saturday

12:00 AM - 12:00 AM NAIC 2019 Spring National Meeting -- JW Marriott/Ritz-Carlton, Orlando, FL

4:00 AM - 6:00 AM FYI: Breakfast - Regulators, Consumer Rep. and NAIC Staff -- Coquina Ballroom South - JW Marriott - Lobby Level

6:00 AM - 6:30 AM Daley -- Cordova 2 room - JW Marriott – Lower Level

6:00 AM - 6:30 AM HOLD for Potential NAIC Meetings -- Cordova 2 – JW Marriott – Lower Level

7:00 AM - 9:00 AM NAIC Joint Meeting of Executive (EX) Committee and Internal Administration (EX1) Subcommittee (Regulator Only) -- Palazzo Ballroom Salons A-C - JW Marriott - Lobby Level

8:00 AM - 10:00 AM FYI: Lunch - Regulators, Consumer Rep. and NAIC Staff -- Coquina Ballroom South - JW Marriott - Lobby Level

9:00 AM - 9:30 AM Meeting with Thomas J. Mays of Government Relations Consulting and Advocacy and his client Genworth -- Cordova 2 room - JW Marriott – Lower Level.

11:00 AM - 11:30 AM Meeting w/ Nelson Taplin Goldwater; NOTE: Dropping by Meeting scheduled w/ Ken Allen -- Cordova 2 – JW Marriott – Lower Level

11:30 AM - 12:30 PM HOLD for Potential Press/Interviews -- Cordova 2 – JW Marriott – Lower Level

12:30 PM - 12:45 PM Meeting with Deborah Darcy, Director of Government Affairs of American Kidney Fund -- Cordova 2 room - JW Marriott – Lower Level

1:00 PM - 2:15 PM Reception/ Meet and Greet w/ Rex NOTE: Meeting w/ Anne Saxon from Nationwide from 5:00 - 5:15pm National Association of Mutual Insurance Companies (NAMIC) Cordova 5 Meeting Room

2:00 PM - 3:30 PM Western Zone Meeting (Regulator Only) -- Mediterranean Ballroom Salon 3 – JW Marriott - Lobby Level

3:30 PM - 4:30 PM NAIC Welcome Reception -- Mediterranean Foyer & Porte-Cochere

4:00 PM - 6:00 PM Dinner with CEO’s -- Vito's Chop House: 8633 International Derive, Orlando Florida, 32819

84

April 7, 2019 Sunday

All Day NAIC 2019 Spring National Meeting -- JW Marriott/Ritz-Carlton, Orlando, FL

4:00 AM - 6:00 AM FYI: Breakfast - Regulators, Consumer Rep. and NAIC Staff -- Coquina Ballroom South - JW Marriott - Lobby Level 2019 NAIC Spring National Meeting April 6-9, 2019 / Orlando, FL

6:00 AM - 9:00 AM Commissioners Roundtable (Regulator Only) -- Mediterranean Ballroom Salons 4-8 - JW Marriott - Lobby Level

8:00 AM - 10:00 AM FYI: Lunch - Regulators, Consumer Rep. and NAIC Staff -- Coquina Ballroom South - JW Marriott - Lobby Level

9:30 AM - 10:30 AM California Delegation Meeting -- Cordova 2 - JW Marriott - Lower Level Time Change: 12:30 to 1:30 pm.

10:00 AM - 10:30 AM Meeting w/ Consumer Liaison's Bonnie Burns; Contact: (this is for 1:00pm Eastern) -- Cordova 2 – JW Marriott – Lower Level

10:30 AM - 11:00 AM Meeting with Barry Weissman re Paradise Policies -- Cordova 2 – JW Marriott –Lower Level

11:00 AM - 12:30 PM FYI: (Not a Member )Life Insurance and Annuities (A) Committee -- Ritz Carlton Ballroom Salons 1-3 - Ritz Carlton - Lobby Level

11:00 AM - 12:00 PM FYI: (Not a Member )NAIC/American Indian and Alaska Native Liaison Committee -- Palazzo Ballroom Salons A-C - JW Marriott - Lobby Level

2019 NAIC Spring National Meeting April 6-9, 2019 / Orlando, FL

11:15 AM - 11:45 AM Meeting w/ Rich Fidel, Fred Karlinsky & Matt Nielsen wRMS Catastrophe Modeling Company -- Cordova 2 JW Marriott, Lower Level

12:30 PM - 2:30 PM FYI: (Not a Member ) Health Insurance and Managed Care (B) Committee -- Ritz Carlton Ballroom Salons 1-3 - Ritz Carlton - Lobby Level

2:00 PM - 2:30 PM Meeting w/ American Property Casualty Insurance Association (APCIA), CEO, Dr. David Sampson, and senior staff -- Monterey Room – JW Marriott – Lower Level

2:30 PM - 3:00 PM NAIC President Eric Cioppa invites you to a Reception for the 2019 Commissioner Mentoring Program -- JW Marriott Hotel – President’s Suite # 25019

4:30 PM - 7:00 PM California Delegation Dinner with Commissioner Ricardo Lara – Seasons 52, 7700 Sand Lake Road, Orlando, FL 32819-5114

85

April 8, 2019 Monday

4:00 AM - 6:00 AM FYI: Breakfast - Regulators, Consumer Rep. and NAIC Staff -- Coquina Ballroom South - JW Marriott - Lobby Level

5:00 AM - 6:30 AM Member NAIC/Consumer Liaison Committee -- Mediterranean Ballroom Salons 4-8 - JW Marriott - Lobby Level

7:30 AM - 9:30 AM Innovation and Technology (EX) Task Force -- Mediterranean Ballroom Salons 4-8 - JW Marriott - Lobby Level

8:00 AM - 10:00 AM FYI: Lunch - Regulators, Consumer Rep. and NAIC Staff -- Coquina Ballroom South - JW Marriott - Lobby Level

9:30 AM - 10:30 AM Financial Condition (E) Committee -- Palazzo Ballroom Salons D&E – JW Marriott - Lobby Level

10:30 AM - 12:00 PM Property and Casualty Insurance (C) Committee -- Ritz Carlton Ballroom Salons 1-3 - Ritz Carlton - Lobby Level

12:00 PM - 2:00 PM FYI: Center for Insurance Policy and Research (CIPR) NAIC Affiliated: Spring Event: How Blockchain is Transforming the Insurance Industry -- Coquina Ballroom North - JW Marriott - Lobby Level

12:00 PM - 1:00 PM Meeting with Commissioners Mike Kreidler and Andrew Stolfi – Commissioners Services Meeting Room

2:00 PM - 3:30 PM FYI: Center for Insurance Policy and Research (CIPR) NAIC Affiliated: Spring Event Reception -- Mediterranean Ballroom Salons 1-3 - JW Marriott - Lobby Level

86

April 9, 2019 Tuesday

12:00 AM - 12:00 AM NAIC 2019 Spring National Meeting -- JW Marriott/Ritz-Carlton, Orlando, FL

4:00 AM - 6:00 AM FYI: Breakfast - Regulators, Consumer Rep. and NAIC Staff -- Coquina Ballroom South - JW Marriott - Lobby Level

6:00 AM - 8:00 AM NAIC Joint Meeting of Executive (EX) Committee and Plenary -- Mediterranean Ballroom Salons 4-8 - JW Marriott - Lobby Level

4:15 PM - 5:45 PM Dinner w/ New York Life, Michael Tobin, Vice President, New York Life Insurance Company, Doug Wheeler, Senior Vice President in New York Life’s Office of Government Affairs, & Alfredo Medina -- ESCA, 402 W 43rd Street, New York City, NY 10036

87

April 10, 2019 Wednesday

9:00 AM - 10:00 AM Lunch w/ Michael McRaith, Managing Director at Blackstone Insurance Solutions, Former Director of the U.S. Treasury’s Federal Insurance Office – Casa Lever, 390 Park Avenue, New York 10022, 53rd street

11:00 AM - 12:00 PM Meeting with the Innovations team from Chubb -- 1133 Avenue of the Americas, 41st Floor New York, NY

3:00 PM - 5:30 PM Dinner with ACLHIC, ACLI & Eric Serna; Contact: Eric Serna -- Edition Hotel, The Clock Tower, Jade Room: 5 Madison Avenue, New York, NY, 10010

88

April 11, 2019 Thursday

7:00 AM - 7:45 AM Meet with The Natural Resources Defense Council (NRDC) at their New York Offices -- 40 West 20th Street (between 5th and 6th Ave) New York, NY 10011

8:00 AM - 9:00 AM Meeting with Environmental Defense Fund -- 257 Park Avenue South, 17th Floor New York, NY 10010

11:00 AM - 12:00 PM Meeting with Dan Firger, Bloomberg Philanthropies about NYC Climate week -- at Madison Ave. New York, NY 10075

3:00 PM - 7:30 PM Hispanic Federation Gala -- American Museum of Natural History, Central Park West at 79th Street, New York City

89

April 12, 2019 Friday

9:00 AM - 10:00 AM Property and Casualty Insurance (C) Committee and Climate Change and Global Working Group Webinar and Call --

90

April 13, 2019 Saturday

10:00 AM - 11:00 AM SPEAK at the United Brotherhood of Carpenters Union Training Center National Day of Action;/Southwest Carpenter's Rally re role of Insurance Commissioner fighting fraud; Contact: Danny Curtain or David Kersh -- Carpenters Union Training Center | 7111 Firestone Blvd, Buena Park, CA 90621

91

April 14, 2019 Sunday

No responsive calendar entries

92

April 15, 2019 Monday

10:30 AM - 11:00 AM Interview re Diversity Task Force -- CRL LA Office, 14th Floor

11:00 AM - 11:30 AM Meet and greet with Pamela Davis, President and CEO of the Nonprofits Insurance Alliance Group and Oscar T. Ramirez, Partner of Fulcrum Public affairs -- CRL DTLA Office

11:30 AM - 12:00 PM Staff Briefing CDI Staff: Catalina, Michael, Tony, Joel, & Ken -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

3:00 PM - 3:50 PM Speak at UCLA Class re SB 1383/short-lived climate pollutants; Contact: Erica -- UCLA 337 Charles E. Young East, Los Angeles, CA 90095 Room #2343 on 2nd floor

93

April 16, 2019 Tuesday

6:00 AM - 3:00 PM Depart for EQCA LGBTQ Trip to the Border -- 11173 Cashmere Street, Los Angeles CA 90049

94

April 17, 2019 Wednesday

2:00 PM - 2:30 PM Call with Daniel Zingale, Office of the Governor

2:30 PM - 3:30 PM Staff Briefing -- SAC-17 Video Conf

95

April 18, 2019 Thursday

No responsive calendar entries

96

April 19, 2019 Friday

10:20 AM - 11:00 AM Hispanos Conectados Roundtable Discussion for Health Promoters and Latino Community Leaders of the Bay area; Contact: Hugo Mata -- Sheriff's Office Assembly Room, 1600 Los Gamos Dr. #200, San Rafael, Ca. 94903

11:00 AM - 11:30 AM Call w/ Mike P

97

April 20, 2019 Saturday

No responsive calendar entries

98

April 21, 2019 Sunday

No responsive calendar entries

99

April 22, 2019 Monday

No responsive calendar entries

100

April 23, 2019 Tuesday

11:00 AM - 11:30 AM Staff Briefing -- CRL's office

11:30 AM - 12:00 PM Meeting w/ AON Reinsurance Solutions (see attendees below) –

SAC-17 Video Conf Rm #17005 (Primary) AON Reinsurance Solutions Bridget Gainer Katie Sabo Steven Goode Bryon Ehrhart Joseph Managhan

12:00 PM - 12:50 PM Assembly Democratic Caucus Lunch -- State Capitol,

1:20 PM - 2:10 PM Speak Panel State Farm Legislative Conference; Contact: Samona -- Sacramento Convention Center, Ballrooms 307-308, 1400 J Street, Sacramento, CA 95814

6:00 PM - 9:00 PM Attend Liberty Hill Foundation Dinner honoring Senator Holly Mitchell as her guest -- The Beverly Hilton, 9876 Wilshire Blvd. Beverly Hills, CA 90210

12:00 PM - 1:00 PM Lunch Meeting with Mark Wiedeman -- Ella Dining Room, 1131 K St., Sacramento

1:30 PM - 2:45 PM Testify on Sponsored Bills at Senate Insurance Hearing -- State Capitol

2:20 PM - 3:10 PM Deputy Commissioner Bryant Henley's Swearing in -- CRL's Office

3:10 PM - 3:30 PM Call w/ Sharon

6:00 PM - 8:00 PM FYI: CLIMATE ACTION RESERVE's NACW 2019 VIP RECEPTION - evite acceptance -- WALT DISNEY CONCERT HALL - FOUNDERS ROOM 111 S GRAND AVELOS ANGELES, CALIFORNIA 90012

101

April 25, 2019 Thursday

8:45 AM - 10:00 AM SPEAK at North American Carbon World's Annual Conference re climate risk and responsibility; Staffing: Mike Peterson; Contact: Sean B. Hecht -- InterContinental (Wilshire Grand Ballroom II) Los Angeles Downtown, 900 Wilshire Boulevard (entrance on the corner of 7th and Figueroa), Los Angeles, CA 90017)

5:30 PM - 6:20 PM Tom Homann LGBT Law Association’s 26th Annual Reception - - U.S Grant Hotel, 326 Broadway, San Diego, CA 92101 US

6:30 PM - 8:00 PM Tom Homann LGBT Law Association’s 26th Annual Dinner (Casey Gerry is the title sponsor) -- US Grant, 326 Broadway, San Diego, CA 92101 US

102

April 26, 2019 Friday

7:50 AM - 9:00 AM Speak + Pre - Interview (interview culturally and linguistically relevant to students) - Maywood Academy High re Various; Contact: Ann -- 6125 Pine Avenue Maywood 90270

10:30 AM - 11:30 AM Speak at 50th Anniversary of the Stonewall Riots and Contributions by LGBTQ Americans -- East Los Angeles College, 1301 Avenida Cesar Chavez, Monterey Park,Room IS F5-201 (MPR Multipurpose Room)

2:00 PM - 2:30 PM Meeting w/ Pacific Life Insurance Company's President and CEO, Jim T. Morris; FYI: Catalina and Michael; Julia to staff -- CRL's LA Office Contact: Sandy Attendees: Pacific Life Insurance Company President and CEO, Jim T. Morris & John Shirikian,Vice President , ACLHIC

Topic: Meet and Greet and about the company and the work they do

103

April 27, 2019 Saturday

3:00 PM - 7:00 PM MECHA de San Diego State University 50th Anniversary: NOTE: CRL speaks at 4:15-4:30pm -- SDSU - 5500 Campanile Dr, San Diego, CA 92182, Storm Hall Terrace (south of building 14)

104

April 28, 2019 Sunday

10:00 AM - 2:30 PM Malibu Insurance Workshop -- Malibu City Hall - 23825 Stuart Ranch Rd, Malibu, CA 90265

105

April 29, 2019 Monday

8:00 AM - 8:45 AM Long-Term Care Insurance (EX) Task Force Call

8:00 AM - 8:30 AM Photo w/ Garfield Band to Present a Donation Check -- Garfield High School

106

April 30, 2019 Tuesday

9:00 AM - 9:30 AM Meeting w/ Topic SB 29 (Durazo) Health for All Adults; FYI for Catalina and Michael; Contact: Leticia Lewis -- Capitol Room 5066

10:00 AM - 10:30 AM Distracted Driving Event with the Auto Club of Southern California – Sacramento; Participants: CHP, Assemblymembers Daly and Frazier, AAA, auto crash survivor advocate, other law enforcement TBD -- State Capitol, east steps

11:00 AM - 11:30 AM Speak at the Allstate insurance Company's Lobby Day -- Cafeteria 15L, 15th and L St.

11:30 AM - 12:15 PM Confirmed Meeting w/ Senator Jim Beall re Policy discussion on SB 11 relating to Mental Health Parity; CDI Staff: Catalina, Michael & Janice -- SAC-17 Video Conf Rm #17005 (Primary)

12:30 PM - 1:00 PM Speak (Keynote) at Consumer Attorney's of California (CAOC) Annual Lobby Day, Justice Day -- Sutter Club, 1220 9th Street, Sacramento, CA

1:15 PM - 2:00 PM Meeting w/ CHP Commissioner Stanley -- 601 North 7th Street, Sacramento, CA 95811

3:30 PM - 4:00 PM Meet and greet with CalVet Secretary Vito Imbasciani, former U.S. Army Colonel, and presently practicing urologic surgeon at Kaiser Permanente and Deputy Secretary John Spangler with the Department of Veteran Affairs -- SAC-17 Video Conf Rm #17005 (Primary)

6:30 PM - 9:30 PM Welcome Dinner -- The Firehouse, 1112 2nd Street, Sacramento, CA 2019 NAIC Wildfire Risk & Resiliency Summit

6:30 PM - 8:00 PM Wildfire Risk and Resilience Summit Dinner -- The Firehouse Restaurant, 1112 2nd Street, Sacramento

107

May 1, 2019 Wednesday

12:00 AM - 12:00 AM California Department of Insurance and NAIC Wildfire Risk & Resiliency Summit -- Paradise, CA

2:00 PM - 3:00 PM Meet with Paradise City Leaders -- Paradise, California 2019 NAIC Wildfire Risk & Resiliency Summit May 1‐2, 2019

3:00 PM - 4:30 PM Bus Tour of Camp Fire Impact, Debris Removal, etc. – Paradise, California 2019 NAIC Wildfire Risk & Resiliency Summit May 1‐2, 2019

4:30 PM - 5:00 PM Bus Transportation to Chico, California -- Paradise, California 2019 NAIC Wildfire Risk & Resiliency Summit May 1‐2, 2019

5:00 PM - 7:00 PM Tour, Tasting, Dinner -- Sierra Nevada Brewing Company 2019 NAIC Wildfire Risk & Resiliency Summit May 1‐2, 2019

108

May 2, 2019 Thursday

12:00 AM - 12:00 AM California Department of Insurance and NAIC Wildfire Risk & Resiliency Summit -- Paradise, CA

8:00 AM - 11:00 AM Presentations and Discussion on Wildfire Impacts, Responses and Recovery -- Embassy Suites - Steamboat/Central Pacific Room - Main Level

11:00 AM - 1:00 PM Closing Lunch -- Embassy Suites - Terrace, 2nd Level

1:00 PM - 3:00 PM Governor's State Employee Medal of Valor Ceremony; -- California Highway Patrol Academy, 3500 Reed Ave, West Sacramento, CA

7:00 PM - 9:00 PM RFK Annual Awards Reception (CRL was selected to receive the Robert F. Kennedy Legacy Award) -- Sportsmen's Lodge Hotel, 12825 Ventura Blvd., Studio City, CA. 91604

109

May 3, 2019 Friday

12:00 PM - 1:30 PM Speak re Community health; Being Honored at the Promise of Care Luncheon; Joshua -- Omni Los Angeles 251 S Olive St, Los Angeles, CA 90012

110

May 4, 2019 Saturday

No responsive calendar entries

111

May 5, 2019 Sunday

No responsive calendar entries

112

May 6, 2019 Monday

12:00 PM - 2:00 PM Lunch w/ only Steve Menzies & Jamie Sahara -- NoMad restaurant 649 S Olive St, Los Angeles, CA, United States, 90014 Contact: Jamie Sahara

2:15 PM - 2:45 PM Conference call with Deputies Mrs. Hayes-Bautista, Mr. Soller, Mr. Peterson

113

May 7, 2019 Tuesday

NAIC All Commissioners DC Fly-In (May 7-9)

3:30 PM - 5:30 PM Reception and Dinner at Joe’s Seafood, Prime Steak & Stone Crab 750 15th St NW Washington, DC 20005 (202) 489-0140 -- 750 15th St NW Washington, DC 20005

114

May 8, 2019 Wednesday

5:30 AM - 9:30 AM Commissioner Workshop, featuring presentations by Congressional and Federal officials -- Top of the Hill at the Reserve Officers Association (ROA). Minuteman Building, Fifth Floor, 1 Constitution Ave. NE

10:00 AM - 2:00 PM HOLD for Capitol Meetings w/ Congressional Delegations

4:00 PM - 6:00 PM Dinner – Capitol View at 400 -- Rooftop of the Hall of States Building 444 North Capitol Street, NW Washington, DC 20001

115

May 9, 2019 Thursday

2:30 PM - 3:00 PM Conference call with Deputies

116

May 10, 2019 Friday

No responsive calendar entries

117

May 11, 2019 Saturday

No responsive calendar entries

118

May 12, 2019 Sunday

No responsive calendar entries

119

May 13, 2019 Monday

10:00 AM - 10:30 AM Meeting with Armand Feliciano -- SAC-17 Video Conf Rm #17005 (Primary)

10:45 AM - 10:55 AM Briefing with Mr. Levy and Catalina -- CRL's office

11:00 AM - 11:30 AM Meet and Greet with Dave Wichmann, UHG CEO -- Il Fornaio, 400 Capitol Mall, Downtown, Sacramento

11:30 AM - 12:00 PM Meeting with Claudia Oliveira, Historic Core Resident Director of DTLA Neighborhood Council -- SAC-17 Video Conf Rm #17005 (Primary)

1:00 PM - 1:15 PM Meeting with Janice; CRL’s office

1:15 PM - 2:00 PM Briefing with Mr. Martinez, Mr. Peterson, Bryant, Catalina

2:00 PM - 2:30 PM Meeting with Phil Walker – SAC-17 Video Conf Rm #17005 (Primary); SF-21 Video Conf Rm #21010 (Primary)

2:45 PM - 3:15 PM Meeting with Catalina, Mr. Martinez, Melissa, Bryant, Nikki

120

May 14, 2019 Tuesday

9:15 AM - 9:30 AM Call with Secretary Alex Padilla

2:30 PM - 3:00 PM Meeting with Assembly Member Buffy Wicks Location: Capitol Office RM 5160

3:30 PM - 4:30 PM Energy Strike Force Meeting – Governor’s Office

121

May 15, 2019 Wednesday

7:30 AM - 5:30 PM 4TH Conference of LGBTI Political Leaders of the Americas -- BOGOTA, Colombia Contact: Ruben J. Gonzales ,Vice President, Victory Institute ,LGBTQ Victory Institute Mario Enriquez, Director of Domestic Programs Alheli Partida

122

May 16, 2019 Thursday

6:30 AM - 11:00 AM CRL Panel: 4th Conference of LGBTI Political Leaders of the Americas - Democracy Demands Equality Conference -- Congress of Columbia - Carrera 8 No. 10 – 7 codigo postal 111711 Agenda: https://liderazgoslgbt.com/en/agenda/ 8:30am; 9:00m; Registration Contact: Alheli Partida Contact: Ruben J. Gonzales ,Vice President, Victory Institute ,LGBTQ Victory Institute

11:00 AM - 12:00 PM Meeting with Congresista Mauricio Toro - Colombia -- Capitolio Nacional de Colombia Cl. 10, Bogotá, Colombia

1:30 PM - 4:00 PM FYI: LGBTI Political Leaders Conference -- Hotel Radisson Ar Bogota Airport, Carrera 60, No. 22-99, Bogota, Columbia Topic: Building a National advocacy work plan with a regional perspective. Contact: Mario Enriquez, Director of Domestic Programs Alheli Partida

5:00 PM - 7:00 PM Cocktail Reception -- Hotel Radisson Ar Bogota Airport, Carrera 60, No. 22-99, Bogota, Columbia

123

May 17, 2019 Friday

6:00 AM - 5:00 PM LLGBTI Political Leaders Conference (Panelist) -- Hotel Radisson Ar Bogota Airport, Carrera 60, No. 22-99, Bogota, Columbia Contact: Ruben J. Gonzales ,Vice President, Victory Institute ,LGBTQ Victory Institute Or Alheli Partida Agenda: https://liderazgoslgbt.com/en/agenda

9:30 AM - 11:00 AM CRL Panel: 4th Conference of LGBTI Political Leaders of the Americas - Democracy Demands Equality Conference -- Hotel Radisson Ar Bogota Airport, Carrera 60, No. 22-99, Bogota, Columbia Contact: Ruben J. Gonzales ,Vice President, Victory Institute ,LGBTQ Victory Institute or Alheli Partida Agenda for the entire conference: here

12:00 PM - 1:00 PM Meeting with David Felipe Olarte Amaya, Jefe de Oficina de Asuntos Internacionales -Ministerio de Ambiente y Desarrollo Sostenible -- Hotel Radisson Ar Bogota Airport Carrera 60, No. 22- 99 Bogota, Colombia

6:00 PM - 8:00 PM Dinner with Victory donors (Gay & Lesbian Victory Fund & Institute) -- Harry Sasson Carrera 9 # 75-70, Bogota, Capital District 111831

8:00 PM - 10:00 PM Evening out in Chapinero, the center of LGBTQ life in Bogota

124

May 18, 2019 Saturday

9:30 AM - 5:00 PM LGBTI Political Leaders Conference -- Hotel Radisson Ar Bogota Airport, Carrera 60, No. 22-99, Bogota, Columbia Agenda:https://liderazgoslgbt.com/en/agenda/ Contact: Jessica Perez, Campaign Strategist & Creative Director Jacobson & Zilber Strategies

5:00 PM - 7:00 PM Closing Party with Samples of the Barranquilla Carnival. (courtesy of Pro Columbia) -- Hotel Radisson Ar Bogota Airport, Carrera 60, No. 22-99, Bogota, Columbia

125

May 19, 2019 Sunday

No responsive calendar entries

126

May 20, 2019 Monday

No responsive calendar entries

127

May 21, 2019 Tuesday

9:15 AM - 9:45 AM Speak at California Association of Health Underwriters (CAHU)'s Annual Capitol Summit; re Overview of goals as Commissioner; Staffing: Janice -- Sawyer Hotel in Sacramento Closed to Media

10:00 AM - 10:45 AM Follow-up to the meeting NY Life with Michael Tobin and Doug Wheeler of Manatt, Phelps& Phillips, LLP- Staff: Catalina, Michael & Susan Bernard -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner) Contact: Tracy Fujii

The attendees would be as follows: Michael Tobin, Vice President; Office of Government Affairs Doug Wheeler, Senior Vice President; Office of Government Affairs Aaron Ball, Senior Vice President; Long Term Care Heather Deichler, Vice President; Long Term Care Alfredo Medina, Manatt Phelps & Phillips

11:00 AM - 11:30 AM Meeting with Donald C. Marshall, Chair of the Fraud Assessment Commission; CDI Staff: Catalina, George and Bryant -- SAC-17 Video Conf Rm #17005 (Primary) Contact: Don

11:30 AM - 11:50 AM Meeting with Richie Ross and Joaquin Ross; CDI Staff: Catalina -- SAC-17 Video Conf Rm #17005 (Primary) Contact; Yecenia

12:00 PM - 12:30 PM Attend National Day of Action against Abortion Bans (electeds get to speak briefly); Contact: Jennifer Wonnacott -- North Steps of the State Capitol

2:30 PM - 3:00 PM FYI: Audit Briefing - LA County Department of Children & Family Services (2018-126); CDI Staff: Michael Soller, Mike Peterson and Bryant Henley; Contact: Edna Aguada -- SAC-17 Video Conf Rm #17005 (Primary)

Attendees from State Auditor’s Office will be:

State Auditor Elaine Howle Paul Navarro, Chief Deputy State Auditor Ralph Flynn, Senior Auditor Heather Kendrick, Assistant Chief Counsel

128

May 22, 2019 Wednesday

8:00 AM - 9:30 AM Attend: Latino State of Census 2020 briefing -- National Press Club, 529 14th Street NW, 13th Floor

11:00 AM - 12:00 PM Speak ); IBT and ILRF Joint Staff Briefing with Congresswoman Napolitano re (SB 1402) Labor contracting: customer liability; Contact: Christina Montorio -- Rayburn Building, Room 2175, 45 Independence Ave SW, Washington, DC 20515, CA

2:30 PM - 5:00 PM Speak at ILRF Annual Labor Rights Defenders Awards -- Studio Theatre 1501 14th St NW Washington DC 20001 Contact: Christina Montorio, International Brotherhood of Teamsters Port Division

129

May 23, 2019 Thursday

6:00 AM - 6:30 AM Meeting w/ Ethan at NAIC Office -- NAIC Office, 444 North Capitol Street, NW, Suite 700

6:45 AM - 7:40 AM Meeting w/ Congresswoman Maxine Waters re Federal issues that are priorities to California and NAIC; Contact: Symonne M. Smith -- Rep Waters Office, 2221 RHOB, Rayburn House Office Building, 45 Independence Ave SW, Washington, DC 20515

6:00 PM - 8:00 PM FYI: (Julia to accept the award on your behalf) Taste of Boyle Heights (Honoring you with the Soaring Eagle Award) -- Casa del Mexicano in Boyle Heights Contact: Naheemah

130

May 24, 2019 Friday

9:00 AM - 9:30 AM Phone Call w/ Natalie L. Wood, COO and Co-Founder, Silicon Valley Insurance Accelerator

10:30 AM - 12:00 PM SPEAK at San Francisco City College Commencement

1:00 PM - 1:45 PM Interview w/ Marisa Lagos w/KQED re Insurance Issues Related to Wildfires -- KQED Studio, 2601 Mariposa Street, San Francisco, CA

2:30 PM - 3:30 PM San Francisco Chronicle Editorial Board Meeting; -- 901 Mission Street, San Francisco, CA

5:00 PM - 5:30 PM Call w/ Nick Roxborough

131

May 25, 2019 Saturday

No responsive calendar entries

132 May 26, 2019 Sunday

No responsive calendar entries

133

May 27, 2019 Monday

Memorial Day Holiday

No responsive calendar entries

134

May 28, 2019 Tuesday

9:00 AM - 10:00 AM Meeting with Jeff Tsai, Attorney representing Prime Health SAC-17 Video Conf Rm #17005 (Primary)

10:30 AM - 11:00 AM Meeting with Pete Carrillo of Silicone Valley Advisor and Joe Coto, former Assembly Member; -- SAC-16 Video Conf Rm #16005 (Secondary)

11:00 AM - 11:30 AM Meet and Greet Health Net Executive Team, Daniel C. Chick, Senior Director of Government Affairs; Carol K. Kim, Vice President of Community Investment,; Jenn A. Moore, Commercial Officer; Steven J. Sell, Chief Executive Officer; Tamie Houser -- SAC-17 Video Conf Rm #17005 (Primary)

2:15 PM - 2:30 PM Staff Briefing -- SF-23 Video Conf Rm (Office of Commissioner); SAC-16 Video Conf Rm #16005 (Secondary)

5:30 PM - 8:00 PM Sonoma County DOI Visit -- 575 Administration Drive, Suite 104A Santa Rosa, CA 95403 Staff: Mr. Soller, Mr. Cignarale

135

May 29, 2019 Wednesday

10:00 AM - 10:45 AM Staff Briefing -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

2:00 PM - 3:00 PM Confirmed Meeting w/ CalEPA's Secretary Jared Blumenfeld -- SAC-17 Video Conf Rm #17005 (Primary) Attendees: Secretary Blumenfeld

5:00 PM - 5:45 PM Drinks w/ Randy Perry, ARA, Damon Kurtz, PORAC VP, & Joey Schlemmer, PORAC Insurance & Benefits Trust Empress Tavern 1013 K St, Sacramento, CA 95814

Attendees: Randy Perry, ARA Damon Kurtz, PORAC VP Joey Schlemmer, PORAC Insurance & Benefits Trust (waiting on confirmation if he is attending)

6:00 PM - 6:45 PM Cocktails with Senator Bradford and Nathalie of Advance America - Zocalo’s at 1801 Capitol Avenue

6:30 PM - 8:00 PM Attend: Senate President pro Tempore Toni Atkins is hosting a dinner for A Delegation of Members of Keidanren (Japan Business Federation); -- Leland Stanford Mansion, 800 N Street • Sacramento, California;

136

May 30, 2019 Thursday

12:00 PM - 1:00 PM Speak at Lunch with Malia Cohen, Chair of State Board of Equalization and Representatives of communities of color from the insurance industry in San Francisco; Julia Staffing -- One Market Restaurant, 1 Market St., San Francisco, 94104

2:00 PM - 3:00 PM Confirmed Meeting w/ Workers' Compensation Insurance Rating Bureau's CEO, Bill Mudge, Chief Actuary, Dave Bellusci and Chief Legal Officer, Brenda Keys re Workers' Compensation Presentation -- SF-23 Video Conf Rm (Office of Commissioner)

137

May 31, 2019 Friday

11:00 AM - 1:30 PM Working out of SF Office

9:00 PM - 11:00 PM LGBTQ Reception from Equality California, the California LGBTQ Legislative Caucus and Senator Scott Wiener -- Oasis- 298 11th St, San Francisco, CA 94103

138

June 1, 2019 Saturday

8:00 AM - 7:00 PM 2019 California Democratic Convention -- MOSCONE CONVENTION CENTER 2019 California Democratic Convention

10:13 AM - 10:50 AM Speaking at General Session-- Moscone Center, Hall F

139

June 2, 2019 Sunday

1:30 PM - 2:30 PM 8th Annual Awards Program (Garfield Alumni Foundation Lunch) Honoring Argelia Atilano; Tonya Martin Staffing CRL, -- Luminarias Restaurant, 3500 Ramona Blvs., Monterey Park 91754

140

June 3, 2019 Monday

1:00 PM - 1:45 PM Meeting w/ Mike P -- CRL's Office

2:30 PM - 3:00 PM Conference Call /Staff Briefing

3:35 PM - 3:50 PM Interview w/ Steve Jaxon, KSRO

3:45 PM - 4:30 PM Briefing w/ Catalina and Michael -- CRL's office

141

June 4, 2019 Tuesday

9:30 AM - 9:45 AM Interview w/ Pat Kerrigan/KSRO Radio

10:30 AM - 11:00 AM California LGBTQ Pride Month Kick-off Presser -- Capitol Mall in the traffic circle between 9th St & 10th St

142

June 5, 2019 Wednesday

9:30 AM - 11:00 AM Lunch w/ Susan B. at Jack Stack Barbecue; Jack Stack Barbecue - Freight House, 101 W. 22 St, Kansas City

11:00 AM - 2:30 PM Long-Term Care Insurance (EX) Task Force (Regulator-to- Regulator meeting)

4:30 PM - 7:30 PM NAIC Dinner and Ballgame - Kansas City Royals vs. Boston Red Sox. First pitch is at 7:15 pm. (Baseball ticket link attached below) - - Kauffman Stadium, Frank White Suite 1 & Signature Suite 21, Kansas City, MO 64129

143

June 6, 2019 Thursday

12:00 AM - 12:00 AM Registration Confirmed - 2019 NAIC/NIPR Insurance Summit -- Kansas City Marriott Downtown, 200 W 12th Street, Kansas City, MO 64105

6:30 AM - 1:30 PM Long-Term Care Insurance (EX) Task Force Meeting (Regulator-to- Regulator)

144

June 7, 2019 Friday

8:30 AM - 9:15 AM SPEAK NAIFA California's Keynote Speaker for their Career Advancement Conference; -- Hyatt Regency, Newport Beach, CA

10:30 AM - 11:00 AM Metromile Meeting w/ Jill Allison Opel w/ Foley and Lardner, LLP; Bryant, Tonya, Adam Gammell and Lynne Wehmueller staffing -- LA-14 Video Conf Rm #14001 (Primary); SAC-17 Video Conf Rm #17005 (Primary)

11:00 AM - 11:30 AM Meet and Greet with Michael Rosenfield of Sidley Austin and Associates of Kemper Corporation; Julia, Tonya, Adam Gammell, Rick Holdbrook and Lynn Wehmueller staffing -- SF-21 Video Conf Rm #21010 (Primary); LA-14 Video Conf Rm #14001

Attendees: Duane Sanders, President of the P&C Division, Amy Condo, General Counsel of the P&C Division from Kemper and Michael Rosenfield of Sidley Austin LLP

12:00 PM - 12:30 PM Confirmed: Meeting re WCIRB Governing Committee; Staff: Tonya

12:30 PM - 12:35 PM Garfield High School Band Plaque Presentation; Paul Baily, Band Leader; -- LA Office of the Commissioner

9:00 PM - 11:00 PM Paula Abdul Concert - West Hollywood Park

145

June 8, 2019 Saturday

No responsive calendar entries

146

June 9, 2019 Sunday

8:00 AM - 8:45 AM Breakfast w/ HRC (Human Rights Campaign) before the parade; Tonya staffing CRL -- Vinadore Cafe, 8157 Santa Monica Blvd, West Hollywood, CA 90046

10:00 AM - 1:00 PM March w/ the EQCA & Stonewall Democratic Club in the 2019 LA Pride Parade; Contact: Jane Wishon at or Jeremy Payne directly at1202 N. Crescent Heights Boulevard, West Hollywood, CA 90069

147

June 10, 2019 Monday

9:45 AM - 10:30 AM Staff Briefing CDI Staff: Catalina, Michael, Tony, Joel, Mike P, Bryant, and Ken -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary)

11:00 AM - 2:30 PM HOLD to Prepare for Senate Hearing

3:00 PM - 4:00 PM SELECT COMMITTEE ON GOVERNOR'S 2019 REPORT: WILDFIRES AND CLIMATE CHANGE - CALIFORNIA'S ENERGY FUTURE -- State Capitol, Room 112

148

June 11, 2019 Tuesday

11:00 AM - 11:45 AM Meeting w/ Mike P -- CRL's Office

12:00 PM - 12:15 PM Staff Briefing; CDI Staff: Catalina, Michael & Bryant -- CRL's office

5:30 PM - 7:00 PM FYI- John Laird for Senate reception -- State Building & Construction Trades Council of California 1231 I Street, Suite 302 Sacramento

149

June 12, 2019 Wednesday

9:00 AM - 10:00 AM Staff Briefing -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary)

10:00 AM - 10:45 AM Meeting w/ Tracie Riggs, Tuolumne County Administrator; Attendees below; CDI Staff: Catalina, Tony, Michael and Joel -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner) Attendees: 1. Sherri Brennan, Supervisor District 1 Tuolumne County 2. Tracie Riggs, CAO – Tuolumne County 3. Eric Erhardt, Asst. CAO – Tuolumne County 4. Sarah Carrillo, County Counsel – Tuolumne County 5. Chuck Iley, CAO – Amador County 6. Dallin Kimble, CAO – Mariposa County 7. Don Ashton, CAO – El Dorado County 8. Nicole Williamson, CAO – Alpine County 9. Al Alt, CAO – Calaveras County

10:45 AM - 11:00 AM Staff Briefing CDI Staff: Catalina, Janice, Ken and Tony -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary); SF- 23 Video Conf Rm (Office of Commissioner)

11:00 AM - 12:00 PM Reception for Senate-Elect Lena Gonzales -- State Capitol, Room 211

12:00 PM - 1:00 PM Swearing in of Senator-Elect Lena Gonzalez and Senator-Elect Brian Dahle -- State Capitol

2:00 PM - 2:30 PM Meet and Greet with Assemblymember Brian Maienschein , District 77th ; Catalina staffing -- SAC-17 Video Conf Rm #17005 (Primary)

2:30 PM - 3:00 PM Meeting CalChiro and Bethany Heckman of Weidman Group; re: Essential Health Plan Benefit package -- SAC-17 Video Conf Rm #17005 (Primary)

7:00 PM - 9:00 PM Dinner for Senator-Elect Lena Gonzalez -- Firehouse, 1112 2nd St, Sacramento, CA 95814

150

June 13, 2019 Thursday

8:45 AM - 10:15 AM Speak (Keynote) at the WCIRB Annual Conference re His Vision for the Industry; per CRL (1/17);, work w/ COMMS; Arrive at (arrive by 8:45) Event begins at 9:00 -- The Bently Reserve, 301 Battery St Ste 1, San Francisco, CA 94111, The Former San Francisco Federal Reserve, San Francisco, CA

151

June 14, 2019 Friday

11:00 AM - 11:30 AM Speak) Climate Resolve's "What Can Cities do about Wildfires";; Julia Staffing CRL -- Cathedral of Our Lady of the Angels, 555 West Temple Street, Los Angeles, CA, US, 90012

6:00 PM - 9:00 PM San Diego Equality Awards (in Nora Vargas honor) -- (Humphrey's By The Bay) 2241 Shelter Island Dr, San Diego, CA 92106

152

June 15, 2019 Saturday

9:00 PM - 11:00 PM Dinner with David Vela and Alfredo Medina from Mannatt -- Blacksmiths Restaurant - 117 Winston St., Los Angeles

153 June 16, 2019 Sunday

No responsive calendar entries

154

June 17, 2019 Monday

9:15 AM - 10:00 AM Meeting w/ Ms. Kristen Miranda, CA President for Aetna & J. Kevin Pedrotti; CDI Staff: Janice; Contact: Kevin -- SAC-17 Video Conf Rm #17005 (Primary) Kristen Miranda, California President & West Territory Head Rajini Sharma, West Region Counsel Sunshine Moore, Sr. Director, State Government Affairs Kevin Pedrotti, JK Pedrotti, Inc.

10:00 AM - 10:30 AM Conference Call w/ Fire Chief Michael Schwartz, North Tahoe Fire Protection District re Non-renewals; Kelly McElravey;

10:30 AM - 11:00 AM Meet w/ Mike Peterson -- CRL's office

11:00 AM - 11:20 AM Meet and Greet with Joe Torti w/ Fairfax Financial Holdings Limited

Attendees: Nick Bentley – Riverstone ‐ President and CEO Debbie Irving – Riverstone ‐ Executive Vice President, Chief Corporate Operations Officer & Chief Financial Officer John Bauer – Riverstone – Vice President and Deputy General Counsel, Corporate Legal Joe Torti – Fairfax – Vice President Regulatory Affairs

11:30 AM - 12:00 PM Staff Briefing -- CRL's office

2:30 PM - 4:30 PM Confirmed Sexual Harassment and Discrimination Prevention Training; NOTE: LA VC Set up for LA Staff -- SAC-13 Video Conf Rm #13025; LA-14 Video Conf Rm #14001 (Primary)

5:30 PM - 6:30 PM Dinner w/ Rex Frazier -- Waterboy 2000 Capitol Ave

155

June 18, 2019 Tuesday

1:00 PM - 2:00 PM California Commission on Aging (Former Assembly Member Betsy Butler requesting for you to speak before her Commission; Julia or Tonya staffing CRL -- Thousand Oaks Inn, 75 W. Thousand Oaks Blvd., Thousand Oaks, CA 91360 - Garden Room

156

June 19, 2019 Wednesday

10:45 AM - 12:15 PM Speak at InsurTech Climate Change & Insurance: Protecting Our Future; Contact: Natalie; Aaron Staffing CRL - -- South San Francisco Conference Center, 255 South Airport Boulevard, South San Francisco, CA 94080

157

June 20, 2019 Thursday

No responsive calendar entries

158

June 21, 2019 Friday

No responsive calendar entries

159

June 22, 2019 Saturday

No responsive calendar entries

160

June 23, 2019 Sunday

No responsive calendar entries

161

June 24, 2019 Monday

11:00 AM - 11:30 AM Meeting with Melissa Cortez of Governmental Advocates and Kurt Stembridge of Greenwich Biosciences -- SAC-17 Video Conf Rm #17005 (Primary)

11:30 AM - 12:45 PM Lunch with LGBTQ Caucus Members -- Third floor of the historic side, Room 317

1:00 PM - 2:00 PM Joel's Retirement Party -- SAC 13

5:30 PM - 7:30 PM CA Legislative LGBTQ Caucus 2019 Pride Ceremony -- Governor's Mansion 1526 H Street, Sacramento, CA

162

June 25, 2019 Tuesday

12:00 AM - 12:00 AM Executive Committee (ExCo) Interim & Mid-Year All Commissioners Roundtable -- Rockland, ME

7:30 AM - 8:00 AM 2023 National Meeting bid presentations -- Knox County Ballroom, Lower Level West Wing

8:15 AM - 8:25 AM Welcome and Opening Remarks (Superintendent Eric A. Cioppa (ME), NAIC President) -- Knox County Ballroom, Lower Level, West Wing

8:25 AM - 9:15 AM Long-Term Care Insurance (Commissioner Scott A. White (VA)) -- Knox County Ballroom, Lower Level, West Wing

9:15 AM - 10:15 AM Lunch for Meeting Attendees and Guests -- Bay Point Ballroom, Upper Level, West Wing

10:15 AM - 11:15 AM Long-Term Care Insurance (cont’d) (Commissioner Scott A. White (VA)) -- Knox County Ballroom, Lower Level, West Wing

11:15 AM -12:15 PM Health Insurance (Commissioner Jessica Altman (PA)) Knox County Ballroom, Lower Level, West Wing

12:15 PM - 1:15 PM Canceled: Plenary (NAIC)

12:15 PM - 12:45 PM Plenary -- Knox County Ballroom, Lower Level West Wing

1:00 PM - 2:00 PM Western Zone Meeting -- Vinalhaven, Lower Level, West Wing

3:00 PM - 6:00 PM Conference Welcome Reception and Dinner for All Attendees and Guests -- Samoset - Penobscot Bay Patio

163

June 26, 2019 Wednesday

All Day Executive Committee (ExCo) Interim & Mid-Year All Commissioners Roundtable -- Rockland, ME

4:30 AM - 5:30 AM FYI: Breakfast for Meeting Attendees and Guests -- Bay Point Ballroom, Upper Level, West Wing

4:30 AM - 5:30 AM FYI: Compact Strategy Session -- Penobscot Bay Room at the Samoset Resort in Rockport, Maine

5:30 AM - 6:30 AM Data, Innovation & Cyber (Michael Consedine, NAIC CEO Scott Kosnoff, Partner, Faegre Baker Daniels, LLP) -- Knox County Ballroom – Lower Level, West Wing

6:30 AM - 6:45 AM Morning Break

6:45 AM - 7:30 AM Annuity Suitability (Director Jillian Froment (OH)) -- Knox County Ballroom – Lower Level, West Wing

7:30 AM - 9:00 AM Panel Discussion: "A Better Understanding of Climate Risks" Moderator: Superintendent Beth Dwyer(RI) -- Knox County Ballroom – Lower Level, West Wing

9:00 AM - 10:15 AM Lunch for Meeting Attendees and Guests -- Bay Point Ballroom, Upper Level, West Wing

10:15 AM - 11:15 AM Standing Committees - First Breakout Session (A, E and G Committees) -- Knox County Ballroom – Lower Level, West Wing

11:15 AM - 11:30 AM Afternoon Break

11:30 AM - 12:30 PM Standing Committees - Second Breakout Session (B, C and D Committees) -- Knox County Ballroom – Lower Level, West Wing

12:30 PM - 1:00 PM Regroup and Wrap-Up on Standing Committee Discussions -- Knox County Ballroom – Lower Level, West Wing

3:30 PM - 6:00 PM Commissioners Reception and Dinner for All Attendees and Guests -- Point Lookout - The Summit

4:00 PM - 7:00 PM FYI: World Pride Opening Ceremony; Tonya is attending with Parliament Member Alex Greenwich - : 7:00 PM - 10:00 PM (EST) -- Barclays Center, 620 Atlantic Ave, Brooklyn, NY 11217

164

June 27, 2019 Thursday

12:00 AM - 12:00 AM Executive Committee (ExCo) Interim & Mid-Year All Commissioners Roundtable -- Rockland, ME

4:30 AM - 5:30 AM FYI: Breakfast for Meeting Attendees and Guests -- Bay Point Ballroom, Upper Level West Wing

5:30 AM - 6:15 AM FYI: International Insurance Issues (Commissioner Gary D. Anderson (MA)) -- Knox County Ballroom – Lower Level, West Wing

6:15 AM - 6:45 AM Group Capital Calculation (Commissioner David Altmaier (FL)) -- Knox County Ballroom – Lower Level, West Wing

6:45 AM - 7:00 AM RegTech (Andy Beal (NAIC)) -- Knox County Ballroom – Lower Level, West Wing

7:00 AM - 9:00 AM FYI: Stonewall National LGBTQ Wall of Honor - 10:00 am/EST -- The Stonewall Inn, 53 Christopher St. New York, New York 10014

7:00 AM - 7:15 AM Morning Break

7:15 AM - 7:45 AM Pharmacy Benefit Manager Regulation (Commissioner Andrew Stolfi (OR)) -- Knox County Ballroom – Lower Level, West Wing

7:45 AM - 8:00 AM FYI: NAIC Designation Program (Trish Schoettger (NAIC)) -- Knox County Ballroom – Lower Level, West Wing

8:00 AM - 8:15 AM NAIC Disaster Assistance Program (Trish Schoettger (NAIC)) -- Knox County Ballroom – Lower Level, West Wing

8:15 AM - 8:45 AM FYI: (Hold for additional discussion items) -- Knox County Ballroom – Lower Level, West Wing

8:45 AM - 9:00 AM FYI: Wrap-up -- Knox County Ballroom – Lower Level, West Wing

2:00 PM - 4:00 PM Speaking (at 6pm) at World Pride Reception: Honoring LGBTQ Elected Official’s, Presented by Google - 5:00 PM - 7:00 PM (EST) -- Google HQ, 111 Eighth Ave, New York, NY 10011

165

June 28, 2019 Friday

8:00 AM - 10:00 AM Speak/Attend: Sister City Brunch hosted by Ricardo Lara and Alex Greenwich (Independent Member for Sydney) - 11:00 AM - 1:00 PM (EST) -- Bowery Road, 132 4th Avenue, New York, New York

2:30 PM - 3:30 PM Happy Hour/Dinner with Sponsors & CA LGBTQ Caucus - 5:30 PM (EST) -- Buddakan NYC, 75 9th Avenue, New York, NY 10011

3:00 PM - 6:00 PM Rally: Stonewall 50 Commemoration (OPTIONAL); NOTES: Tonya is in the process of securing a speaking opportunity for the Commissioner. - 6:00 PM - 9:00 PM (EST) -- Christopher St & Waverly Pl

5:00 PM - 6:30 PM FYI: To Kill a Mockingbird (SPONSORS ONLY); NOTE: If Commissioner Lara speaks at Stonewall 50 event he will not be attending - : 8:00 PM (EST) -- Shubert Theatre, 225 W 44th St, New York, NY 10036

166

June 29, 2019 Saturday

11:00 AM - 7:00 PM VIP ROOFTOP - With DJ sets by DJ Grind, DJ Toy Armada, DJ Ben Baker, and DJ Kitty Glitter - Starts at 2pm -10pm (EST) -- The Park 118 10th Avenue, New York, NY 10011

1:00 PM - 4:00 PM Mets vs. Braves - Baseball Game - 4:00 PM (EST) -- Citi Field (Seated in Sterling Suite 9) - 120-01 Roosevelt Ave., Queens, NY 11368

167

June 30, 2019 Sunday

8:00 AM - 3:00 PM PrideFest - WorldPride NYC | Stonewall50: Note: the Veronica's will be performing; 11:00am to 6:00pm (EST) -- 4th Ave, B/w Union Square and Astor Pl https://2019‐worldpride‐ stonewall50.nycpride.org/events/pridefest/

3:30 PM - 5:30 PM MARCH WITH VICTORY IN THE NEW YORK CITY PRIDE PARADE

4:00 PM - 7:00 PM World Pride Closing Ceremony - 7:00-10:00 PM ET -- Times Square

168

July 1, 2019 Monday

No responsive calendar entries

169

July 2, 2019 Tuesday

1:30 PM - 2:00 PM Call w/ Ann O’Leary and Rachel Wagoner

2:30 PM - 3:00 PM Meet w/ Mike Peterson -- CRL's office

170

July 3, 2019 Wednesday

12:00 PM - 1:00 PM Lunch with Antonia Hernandez; Checkers Downtown, 535 South Grand Ave., Los Angeles, CA 90071

3:30 PM - 4:00 PM Phone call with Elaine Howell (State Auditor)

171

July 4, 2019 Thursday

Holiday

No responsive calendar entries

172

July 5, 2019 Friday

No responsive calendar entries

173

July 6, 2019 Saturday

No responsive calendar entries

174

July 7, 2019 Sunday

No responsive calendar entries

175

July 8, 2019 Monday

9:30 AM - 10:00 AM Interview (by phone) w/ Thomas Fuller, New York Times re Wildfire Season -- CRL's office

10:00 AM - 10:30 AM Meeting with Shaun Flanigan of Capitol Strategic Advisors -- SAC- 17 Video Conf Rm #17005 (Primary)

10:30 AM - 11:00 AM Meeting w/ Root CEO, Alex Timm along with Alfredo Medina -- SAC-17 Video Conf Rm #17005 (Primary)

11:30 AM - 1:30 PM Ethics Training 1.5 - 2 hours

2:00 PM - 2:45 PM Confirmed: Meet and Greet with New CalHR Director; Eraina Ortega, Director

176

July 9, 2019 Tuesday

11:00 AM - 11:45 AM Staff Briefing -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner);

1:00 PM - 1:30 PM Record Video for California Earthquake Authority (CEA) -- TBD

2:00 PM - 3:00 PM Meeting w/ Michael S. Gugig, VP, State Government Relations & Associate General Counsel, Transamerica re Long Term Care; Marie Roche - John Hancock government affairs and Chair of AHIP’s LTC Committee, Jan Graeber, ACLI senior actuary & fmr chief actuary -- SAC-17 Video Conf Rm #17005 (Primary)

Attendees: Michael S. Gugig, VP, State Government Relations & Associate General Counsel, Transamerica Marie Roche ‐ John Hancock government affairs and Chair of AHIP’s LTC Committee, Jan Graeber, ACLI senior actuary and former chief actuary for the TX Department; Amanda Matthiesen of AHIP, and Ray Nelson (by phone) AHIP consulting actuary.

CDI Staff: Catalina and Michael

3:00 PM - 3:30 PM CDI-CEA Meeting

177

July 10, 2019 Wednesday

6:15 PM - 7:00 PM Honoring CRL with the Community Leadership Award from the Orange County Lavender Bar Association -- The Sky Garden at the Michelson Building, 3161 Michaelson Drive , Irvine, Ca

178

July 11, 2019 Thursday

8:30 AM - 9:00 AM Confirmed Speaker (provide welcoming remarks) at National Counsel of Insurance Legislators Summer National Meeting; Julia staffing CRL -- Newport Beach Marriott Hotel and Spa

10:30 AM - 11:00 AM CRL and Glenn Pomeroy conduct joint media briefing to discuss the role of earthquake insurance in the recovery process -- CDI LA Office

2:00 PM - 2:30 PM Conducts follow-up media calls while in transit

4:30 PM - 5:00 PM Interviews with Telemundo and Univision -- Kerr McGee Community Center, 100 W California Ave, Ridgecrest, CA 93555

5:00 PM - 5:29 PM Briefing w/ Mayor Peggy Breeden, Jed McLaughlin, Police Chief, City Manager and local business owners -- 100 West California Avenue, Ridgecrest, California, 93555

5:30 PM - 6:00 PM Meet with Norma Vega Kerr McGee Community Center, 100 W California Ave, Ridgecrest, CA 93555

6:00 PM - 7:15 PM Help serve dinner to earthquake victims staying at the shelter -- Kerr McGee Community Center, 100 W California Ave, Ridgecrest, CA 93555

179

July 12, 2019 Friday

No responsive calendar entries

180

July 13, 2019 Saturday

No responsive calendar entries

181

July 14, 2019 Sunday

No responsive calendar entries

182

July 15, 2019 Monday

9:45 AM - 10:00 AM Phone call with Nick Roxborough --

2:00 PM - 2:30 PM Call w/ Catalina and Bryant

183

July 16, 2019 Tuesday

10:30 AM - 11:45 AM Site Visit of Los Angeles Children Hospital (take a tour of the hospital, share your vision of health insurance policy in California and meet administration, physicians, patients and staff); CDI Staff: Tonya -- Los Angeles Childrens Hospital, 4650 Sunset Blvd., Los Angeles 90027

2:00 PM - 3:00 PM AltaMed Filming ( Message from CRL for the 50th Year Anniversary Gala Dinner Video) -- Governor's Press, Office LA Office Building

184

July 17, 2019 Wednesday

10:00 AM - 10:30 AM Meeting with Brian Ternan, Ca. Commercial State Plan President and Michael Prosio, Regional Vice President of Government Affairs for Anthem -- LA-14 Video Conf Rm #14001 (Primary); SAC-17 Video Conf Rm #17005 (Primary)

10:30 AM - 11:00 AM Interview w/ Ryan Sabalow & Dale Kasler w/ Sacramento Bee; re Wildfire insurance availability and affordability;

11:00 AM - 11:30 AM Meeting with Farmers CEO Jeff Dailey -- LA Office

11:30 AM - 12:15 PM Meet and greet with the Insurance Rate Analyst Branch -- LA -13 Video Trng Room # 13003 (this room will be connected to the SF- 21 Video Conferance room #21010)

185

July 18, 2019 Thursday

11:00 AM - 11:45 AM Meet w/ CSAA New President and CEO, Tom Troy, Mike Zukerman, Senior VP & GC, Seema Taneja, Assistant GC & Director Governmental Affairs, Dwight Ku, Regional Director Governmental Affairs & Shari McHugh, Contract lobbyist for CSAA Insurance Group -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-14 Video Conf Rm #14001 (Primary)

2:30 PM - 3:00 PM Call w/ Sharon

186

July 19, 2019 Friday

9:30 AM - 10:00 AM Scheduling Meeting w/ David and Roberta -- CRL's office

10:00 AM - 10:45 AM Meeting w/ Thomas J. Mayes & Genworth's President & CEO Tom McInerney; David O'Leary, President & CEO, US Life Insurance; Matt Kepler, President- Closed Block; Lynn White, SVP & Chief of Staff to CEO; CDI Staff: Catalina, Michael, Ken, Susan & Perry -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-9 Video Conf Rm #9001 (Secondary)

10:45 AM - 11:15 AM Briefing -- CRL's Office

11:30 AM - 12:00 PM Briefing; CDI Staff: Catalina, Bryant and Camilo -- SAC-17 Video Conf Rm #17005 (Primary) 12:00 PM - 12:30 PM Briefing; CDI Staff: Catalina, Michael, Bryant, Amorette, Camilo and Camille -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

5:30 PM - 7:00 PM Welcome remarks at Chicano Latino Youth Leadership Project banquet (speaking at 6:30pm for 15 minutes) -- CSU Sacramento Alumni Center 6000 College Town Dr., Sacramento, 95819

187

July 20, 2019 Saturday

No responsive calendar entries

188

July 21, 2019 Sunday

No responsive calendar entries

189

July 22, 2019 Monday

10:00 AM - 12:00 PM Funeral Liturgy for Barbara Frances Torres -- St. Alphonsus Church 532 S. Atlantic Blvd., LA 90022

190

July 23, 2019 Tuesday

8:30 AM - 8:30 AM Symposium Begins

8:45 AM - 8:45 AM Check in for Keynote 8:45 ‐ check in for keynote

9:00 AM - 5:00 PM Climate Risk Symposium -- UCLA School of Law, Room 1430, 385 Charles E Young Dr E, Los Angeles, CA 90095

9:15 AM - 9:45 AM Opening Keynote Address

10:00 AM - 11:01 AM Panel 1 - Physical Climate Risks, Mitigation, and Insurance

11:30 AM - 12:30 PM Panel 2 - Natural Infrastructure Solutions

12:30 PM - 12:40 PM Dave Jones speaks

12:45 PM - 1:45 PM Lunch

1:45 PM - 2:30 PM Afternoon Keynote: Butch Bacani

2:30 PM - 3:45 PM Panel 3: Managing Physical and Transition Risks and Opportunities

3:45 PM - 4:00 PM Break

4:00 PM - 5:15 PM Roundtable: California Policy Innovations - CRL moderating

5:15 PM - 5:30 PM Closing Remarks

5:30 PM - 6:30 PM Reception for all participants

191

July 24, 2019 Wednesday

9:00 AM - 9:30 AM Welcome Remarks for Bring your Kids to Work Day -- 13th floor Conferance Room - LA

9:30 AM - 10:00 AM Interview w/ Lily Jamali from The California Report (NPR throughout CA)

10:00 AM - 10:30 AM Meet with Secretary Arrellano from Quitana Roo, Mexico to discuss Coral Reef Insurance project; CDI Staff: Mike Peterson -- CRL's office

10:30 AM - 11:30 AM Meet with Butch Bucani (United Nations), Raghuveer Vinokullu (Munich Re), and Saul Gomez (Resources Legacy Fund); Louis Blumberg -- CRL's office

1:00 PM - 1:30 PM Meet with Jeremy McDaniels from the Sustainable Insurance Forum Location: CRL’s LA Office

1:30 PM – 2:00 PM Meet with Raghuveer Vinokullu and Bonnie Guth from Munich CDI Staff: Mike Peterson Location: CRL’s LA Office

2:00 PM - 3:00 PM Meet with Stan Dupre, Clare Murray from Two Degrees Initiative -- CRL's LA Office

3:00 PM - 4:00 PM Ice Cream with CRL and CDI Kids -- LA Executive Office Staff: Julia and Angela

3:00 PM - 3:15 PM Interview w/ Keith Menconi w/KCBS Radio, SF re: partnership w/UN

5:00 PM – 6:00 PM Meet and Greet with Faisal Gill Location: Blue Cow Kitchen and Bar – 350 South Grand Ave., Los Angeles, CA

192

July 25, 2019 Thursday

10:00 AM - 10:30 AM Staff Briefing CRL in LA Office -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary); ORNG-EB Conf Rm

10:30 AM - 11:00 AM Conference Call/Staff Briefing w/Catalina, Bryant, Byron, and Michael Soller -

11:00 AM - 11:45 AM LA Times Editorial Conference Call

1:00 PM - 2:00 PM Speak at the 30th Annual APCIA General Counsel Seminar; -- Loews Hollywood Hotel, located at 1755 N. Highland Ave, Los Angeles, CA 90028 - Studio's A,B & C

3:00 PM - 3:30 PM Call w/ Catalina and Michael re Budget

193

July 26, 2019 Friday

6:00 PM - 9:00 PM East LA Meets NAPA" AltaMed Food & Wine Festival 2019 -- L.A. Live - 800 Olympic Blvd.Los Angeles, CA 90015

194

July 27, 2019 Saturday

12:05 PM - 1:05 PM Staff Briefing w/ Catalina, Bryant, Michael M. -- CRL's office

6:00 PM – 8:00 PM Keynote Speaker at the Calaveras County Democrats Central Committee’s 2nd Annual Fundraising Event Location: Vallecito, CA

195

July 28, 2019 – July 31, 2019 Sunday - Wednesday

No responsive calendar entries

196

August 1, 2019 Thursday

No responsive calendar entries

197

August 2, 2019 Friday

No responsive calendar entries

198

August 3, 2019 Saturday

4:00 AM - 6:00 AM Breakfast - Regulators, Consumer Rep. and NAIC Staff -- Hilton Rhinelander North & Center - 2nd Floor

8:00 AM - 10:00 AM Lunch - Regulators, Consumer Rep. and NAIC Staff -- Hilton Rhinelander North & Center - 2nd Floor

10:00 AM - 11:00 AM NAIC Opening Session -- Grand Ballroom - 3rd Level

12:00 PM - 1:00 PM Climate Risk and Resilience (C) Working Group -- Sutton North & Beekman - 2nd Level

1:00 PM - 1:30 PM Meeting w/ New York Superintendent Lacewell to Discuss Priorities -- Lincoln Room on the 4th Floor

2:30 PM - 3:30 PM Western Zone Meeting (Regulator Only) -- Sutton Center - 2nd Level The Western Zone financial statements June 25 Mid‐Year Zone Meeting Minutes

3:30 PM - 4:30 PM NAIC Welcome Reception -- Rhinelander Gallery - 2nd Level

199

August 4, 2019 Sunday

4:00 AM - 6:00 AM Breakfast - Regulators, Consumer Rep. and NAIC Staff -- Hilton Rhinelander North & Center - 2nd Floor

6:00 AM - 9:00 AM Commissioners Roundtable (Regulator Only)

8:00 AM - 10:00 AM Lunch - Regulators, Consumer Rep. and NAIC Staff -- Hilton Rhinelander North & Center - 2nd Floor

9:00 AM - 10:00 AM California Delegation Meeting -- East Suite - 4th Floor

10:00 AM - 11:00 AM Long-Term Care (EX) Task Force -- America's Hall II - 4th Level

11:00 AM - 11:30 AM Meeting w/ Jonathan Dixon, International Association of Insurance Supervisors (IAIS) Secretary General; -- East Suite – NY Hilton Midtown – 4th Floor.

11:30 AM - 11:50 AM Meeting w/ NAIC Consumer Representatives; Contact: Brendan Bridgeland, Center for Insurance Research, NAIC Consumer Representative, -- East Suite – NY Hilton Midtown – 4th Floor.

200

August 5, 2019 Monday

4:00 AM - 6:00 AM Breakfast - Regulators, Consumer Rep. and NAIC Staff -- Hilton Rhinelander North & Center - 2nd Floor

8:00 AM - 10:00 AM Lunch - Regulators, Consumer Rep. and NAIC Staff -- Hilton Rhinelander North & Center - 2nd Floor

10:00 AM - 10:30 AM Financial Condition (E) Committee -- Gramercy - 2nd Level

10:30 AM - 12:00 PM Property and Casualty Insurance (C) Committee -- America's Hall II - 4th Level

12:30 PM - 1:15 PM NAIC Podcast Interview - "Climate Resilience" -- Concourse E Meeting Room, Concourse Level, New York Hilton Midtown -- 1335 6th Avenue, New York, NY 10019

201

August 6, 2019 Tuesday

4:00 AM - 6:00 AM Breakfast - Regulators, Consumer Rep. and NAIC Staff -- Hilton Rhinelander North & Center - 2nd Floor

6:00 AM - 8:00 AM NAIC Joint Meeting of Executive (EX) Committee and Plenary

202

August 7, 2019 Wednesday

9:30 AM - 10:30 AM Meeting with Placer County Supervisors Kirk Uhler, Cindy Gustafson - Lisa Burlison -- Placer County Administrative Offices, 175 Fulweiler Avenue, Auburn CA

The following will be in attendance: Todd Leopold, Placer County Executive Officer Kirk Uhler, Supervisor, District 4 (Board Chair) Cindy Gustafson, Supervisor, District 5 Bekki Riggan, Deputy CEO (Public Health & Safety) Holly Powers, Assistant Director of Emergency Services Joel Joyce, Management Analyst/Legislative Jane Christenson, Assistant County Executive Officer Sarah Pointdexter, Management Analyst

11:30 AM - 12:30 PM Meeting with Nevada County Supervisors Dan Miller, Ed Scofield -- Nevada County Eric Rood Administrative Center 950 Maidu Avenue, Suite 200 (2nd Floor) Nevada City, CA 95959 (Board's Conference Room) Attendees: Supervisors Dan Miller and Supervisor Ed Scofield CEO Alison Lehman Clerk of the Board Julie Patterson Hunter

2:00 PM - 3:00 PM Meeting with Butte County Supervisors Lambert and Teeter -- 25 County Center Drive, Oroville, CA 95965 Staff: Michael, Tony, Allison Board Chair, Supervisor Steve Lambert Vice Chair, Supervisor Doug Teeter Chief Administrative Officer, Shari McCracken Assistant Chief Administrative Officer, Brian Ring Deputy Chief Administrative Officer, Casey Hatcher

203

August 8, 2019 Thursday

No responsive calendar entries

204

August 9, 2019 Friday

10:00 AM - 12:30 PM Santa Barbara/Montecito Roundtable Discussion with Assembly Member Limon -- Montecito Association - 1469 E Valley Rd, Montecito, CA 93108

205

August 10, 2019 Saturday

6:30 PM - 8:00 PM SB 1391 Gathering -- Sherman Oaks, CA

206

August 11, 2019 Sunday

No responsive calendar entries

207

August 12, 2019 Monday

No responsive calendar entries

208

August 13, 2019 Tuesday

1:00 PM - 1:45 PM Meeting w/ CalEPA Secretary Blumenfeld; Contact: Michelle Sinclair -- SAC-17 Video Conf Rm #17005 (Primary)

1:45 PM - 2:45 PM Staff briefing -- CRL's office

3:00 PM - 3:30 PM Confirmed Meeting w/ Ann O'Leary; CDI Staff: Catalina, Michael Martinez, and Mike Peterson -- Governor's Office, State Capitol

4:00 PM - 5:00 PM Staff Briefing

5:00 PM - 5:30 PM Staff Briefing w/ Catalina and Janice -- CRL's Office

209

August 14, 2019 Wednesday

10:00 AM - 11:00 AM Meeting with Tom Mays, Alvarez and Marcel re Long Term Care insolvency; CDI Staff: Catalina, Susan Bernard (participating in LA) -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary)

Attendees from Alvarez and Marsal include: Jim McDermott, Managing Director, Insurance Advisory Services Douglas Greer, Senior Director, company restructuring, financial, operational and strategic advisory; Scott Harrison, Senior Advisor and former Deputy Superintendent of the New York State Insurance Department and Deputy Commissioner of the Delaware Insurance Department; Tom Mays, Consultant

1:00 PM - 2:00 PM Scheduling Meeting w/ David and Roberta -- CRL's office

210

August 15, 2019 Thursday

10:00 AM - 11:00 AM Meeting w/ Calaveras County including Greg Pryor (other attendees below); CDI Staff: Catalina, Michael M, Joel, Mike Peterson and Tony -- SAC-17 Video Conf Rm #17005 (Primary); LA- 14 Video Conf Rm #14001 (Primary); SF-23 Video Conf Rm (Office of Commissioner)

Attendees: Greg Pryor, a 38 year retired professional Fire Captain Sac Metro Fire and standing local special district Fire Board member in West Point, Calaveras County Jack Garamendi , County of Calaveras Supervisor District 1 Albert Alt, County Administrator for Calaveras County Chief of Amador County Fire Protection, Chief Walt White Calaveras County of West Point Fire Protection Chief, Terry Miller. Chair of the Amador County FireSafe Council, Pat Minyard The standing Mayor of Jackson Ca, and Insurance professional Connie Gonsalves Also Area Professional Foresters and fire fuel mitigation and resource management specialists.

11:15 AM - 12:00 PM Staff Briefing w/ Legislative Team; CDI Staff: Catalina, Michael, Melissa, Josephine, Kendra and Mel -- SAC-17 Video Conf Rm #17005 (Primary)

1:00 PM - 2:00 PM El Dorado County Meeting with Supervisors -- Conference Room A in the County Government Center, 330 Fair Lane, Placerville CA 95667 Attendees for El Dorado County Meeting on the 15th

Supervisor Brian Veerkamp, Dist. 3 (Vice Chair) Supervisor John Hidahl, Dist. 1 Don Ashton, Chief Administrative Officer Carla Hass, Communications Director Laurel Brent‐Bumb, CEO, El Dorado County Chamber of Commerce (Possible) Representative fr/ EDC Association of Realtors

4:00 PM - 5:00 PM Amador County Supervisors Meeting; Joel to staff -- 810 Court Street, Jackson, CA - Attendees:

District 5 Brian Oneto District 3 Jeff Brown County Administrative Officer Chuck Iley Contact: Jeff Brown

7:30 PM - 8:30 PM Keynote Speaker for the Amador County Democratic Central Committee's 14th annual dinner -- Jackson Rancheria, Casino Resort, Amador County, 12222 New York Ranch Rd, Jackson, CA 95642

211

August 16, 2019 Friday

10:00 AM - 10:45 AM Staff Briefing - -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-14 Video Conf Rm #14001 (Primary)

11:00 AM - 11:30 AM Staff Briefing -- SAC-17 Video Conf Rm #17005 (Primary); CC-EB Conf Rm

212

August 17, 2019 Saturday

9:00 AM - 10:30 AM Speak/Present at Session III - Lessons from the Past: The Evolution of Latino Political Leadership in California -- UCLA Meyer and Renee Luskin Conference Center, Los Angeles, CA

213

August 18, 2019 Sunday

5:00 PM - 6:00 PM Speak (Keynote) at the Peninsula Democratic Coalition Location: Cuesta Park, 165 Cuesta Drive, Mountain View, CA

214

August 19, 2019 Monday

No responsive calendar entries

215

August 20, 2019 Tuesday

7:30 AM - 8:30 AM Confirmed Meeting w/ Ana Matosantos -- Fox and Goose, 1001 R St, Sacramento, CA 95811

216

August 21, 2019 Wednesday

1:30 PM - 2:00 PM Interview Call with Michael Robertson of the California Foundation on the Environment and Economy (CFEE) --

2:30 PM - 3:00 PM Meeting w/ Chubb's Jodi Bond, EVP Global Governmental Affairs, Richard Pike VP and Counsel re Chubb’s New Policy on Coal Underwriting and Investment -- SAC-17 Video Conf Rm #17005 (Primary); LA-14 Video Conf Rm #14001 (Primary)

217

August 22, 2019 Thursday

1:00 PM - 1:30 PM Call w/ Sharon

1:30 PM - 2:00 PM Interview EPRC CEA Position -- CRL's Office

2:00 PM - 2:30 PM Scheduling meeting w/ David and Roberta -- CRL's office

2:30 PM - 3:30 PM Staff Briefing -- CRL’s Office

6:00 PM - 8:00 PM Nevada County Town Hall- Wildfire Insurance Recovery Update- -- Foothill Sierra Event Center in Grass Valley - Nevada County 400 Idaho Maryland Rd, Grass Valley, CA 95945

218

August 23, 2019 Friday

10:00 AM - 10:30 AM Meeting w/ Mike P -- CRL's office

11:45 AM - 12:45 PM Meeting w/ the Governor -- Office of the Governor, State Capitol

4:15 PM - 4:45 PM CDP Rural Caucus Speaking at 4:30pm sharp -- Double Tree by Hilton 2050 Gateway Place, 2nd Level, Fir Room San Jose, CA

219

August 24, 2019 Saturday

No responsive calendar entries

220

August 25, 2019 Sunday

1:00 PM - 2:30 PM Pacific Coast University, School of Law in Long Beach 88th Commencement Ceremony - -- Cal State Long Beach in the Gerald R. Daniel Recital Hall, 1250 N. Bellflower Bllvd. Long Beach, CA 90840

221

August 26, 2019 Monday

11:00 AM - 11:30 AM Meet and Greet with the Consul General of Israel in Los Angeles -- LA Office

12:30 PM - 1:00 PM Staff Briefing

1:00 PM - 1:30 PM Phone call w/ Senate Appropriations Chair Portantino

2:00 PM - 2:30 PM Meeting w/Angela -- CRL’s office

222

August 27, 2019 Tuesday

10:00 AM - 11:30 AM Staff Meeting -- SAC-17 Video Conf Rm #17005 (Primary); SF-23 Video Conf Rm (Office of Commissioner); LA-14 Video Conf Rm #14001 (Primary)

1:45 PM - 2:15 PM Call w/ Assembly Appropriations Chair Lorena Gonzalez-Fletcher

2:15 PM - 3:00 PM Meeting w/ Anna Maubach, w/ Kahn, Soares and Conway, LLP -- SAC-17 Video Conf Rm #17005 (Primary); SF-21 Video Conf Rm #21010 (Primary)

3:00 PM - 3:30 PM Record Our Promise Video -- CRL's office

6:40 PM - 7:35 PM Receive the Dream Maker Award at the Campaign for College Opportunity's 15th Anniversary Celebration -- Crocker Art Museum 216 O St, Sacramento, CA 95814

223

August 28, 2019 Wednesday

10:30 AM - 11:15 AM Scheduling Meeting w/ David and Roberta -- CRL's office

11:30 AM - 12:15 PM Staff Briefing; CDI Staff: Catalina, Mike L. and Ken S. -- SAC-16 Video Conf Rm #16005 (Secondary); SF-23 Video Conf Rm (Office of Commissioner)

3:00 PM - 3:30 PM Check in -- CRL's Office

6:00 PM - 8:00 PM Placer County Listening Tour -- Gold Country Fairgrounds, Placer Hall, 209 Fairgate Road, Auburn, CA 95603 Staff: Tonya /Julia

224

August 29, 2019 Thursday

12:00 PM - 12:30 PM Meeting w/ President pro Tempore Toni G. Atkins -- Capitol Office Room 205

3:00 PM - 4:00 PM Meeting with the Tuolumne County Supervisor’s -- 2 South Green St., 4th floor, Sonora, CA 95370

5:00 PM - 7:00 PM Tuolumne County Insurance Town Hall -- Sonora Opera Hall & Community Center, 250 S Washington St, Sonora, CA 95370 -

225

August 30, 2019 Friday

8:45 AM - 9:15 AM Meeting w/ASM Daly -- State Capitol, Room 3120

226

August 31, 2019 Saturday

No responsive calendar entries

227

EXHIBIT 9

July 19, 2019

VIA EMAIL AND OVERNIGHT DELIVERY

Ms. Chao Lor California Department of Insurance 300 Capitol Mall, Suite 1700 Sacramento, CA 95814 Email: [email protected] Tel.: (916) 492-3207

RE: Public Records Act Request

Dear Ms. Lor,

Pursuant to Government Code section 6253, subdivision (b) of the Public Records Act (“PRA”), and Article 1, section 3 of the California Constitution, Consumer Watchdog hereby requests copies of the following records:1

All e-mail or any other communications (“Communications”) between Insurance Commissioner Lara or his representatives, including staff of the Department, and the following individuals: Steven M. Menzies, Jeffrey A. Silver, Stephen Acunto, Carole Acunto, Carl DeBarbrie, Theresa DeBarbrie, Sidney R. Ferenc, Jon M. McCright, Marc M. Tract, Robert L. Stafford, Justin N. Smith, Darlene Graber, or Larry R. Graber. This request also includes Communications between Insurance Commissioner Lara or his representatives, including staff of the Department, and any individuals employed by or representing Applied Underwriters, California Insurance Company, Constitution Insurance Company, or Independence Holding Company. This request includes, but is not limited to, records providing the identities of the individuals participating in the Communications, the topics of those Communications, and the contents of those Communications. This request includes, but is not limited to, any Communications regarding matters pending before the Department, including before the Administrative Hearing Bureau. This request seeks records from January 7, 2019 to the present.

Please note that this letter constitutes a new PRA request. However, as pointed out in our July 11, 2019 letter regarding PRA-2019-00555, each of the individuals and companies identified in this revised request raises significant public interest issues, as it

1 As used in this letter, the term “records” includes writings and correspondence that are printed, typed, hand-written, facsimiles, or computer-generated e-mail.

Ms. Lor Chao California Department of Insurance July 19, 2019 Page 2 of 2

appears these individuals and companies were attempting to inappropriately influence Commissioner Lara’s decision-making on important public matters in violation of state and federal law.

Consumer Watchdog requests these records in an electronic format such as a Portable Document Format (“PDF”).

Any records withheld from production for inspection should be separately identified and should be accompanied by the claimed justification for withholding those records as required by Government Code section 6255. The justification should state the nature of the record withheld and the specific exemption under which the record is being withheld, and provide an explanation of why the public interest is served by withholding the record. We reserve the right to appeal the Department’s decision to withhold any materials.

Should you contend that a portion of a particular record is exempt from disclosure, pursuant to Government Code section 6253, subdivision (a) the exempt portion should be redacted and the remaining portion be produced for inspection.

Consumer Watchdog is prepared to pay reasonable search and duplication fees in connection with this request. However, agencies have discretion to waive fees in order to provide greater access to public records pursuant to Government Code section 6253, subdivision (e). (See North Co. Parents Org. v. California Dep’t of Educ. (1994) 23 Cal.App.4th 144, 148.) As the information that is the subject of this request is of primary benefit to the public, we ask that the Department waive all search and duplication fees.

Consistent with Government Code section 6253, subdivision (c), we expect to hear from the Department within ten days. If you have any questions regarding this PRA request, please contact me at (310) 392-2632 or [email protected].

Respectfully submitted,

Jerry Flanagan

EXHIBIT 10

RICARDO LARA CALIFORNIA INSURANCE COMMISSIONER

September 16, 2019

Jerry Flanagan ([email protected])

SUBJECT: PRA-2019-00697

Dear Mr. Flanagan: On July 19, 2019, the California Department of Insurance ("Department") received your Public Records Act request in the above referenced matter.

Specifically, your request seeks: All e-mail or any other communications ("Communications") between Insurance Commissioner Lara or his representatives, including staff of the Department, and the following individuals: Steven M. Menzies, Jeffrey A. Silver, Stephen Acunto, Carole Acunto, Carl DeBarbrie, Theresa DeBarbrie, Sidney R. Ferenc, Jon M. McCright, Marc M. Tract, Robert L. Stafford, Justin N. Smith, Darlene Graber, or Larry R. Graber. This request also includes Communications between Insurance Commissioner Lara or his representatives, including staff of the Department, and any individuals employed by or representing Applied Underwriters, California Insurance Company, Constitution Insurance Company, or Independence Holding Company. This request includes, but is not limited to, records providing the identities of the individuals participating in the Communications, the topics of those Communications, and the contents of those Communications. This request includes, but is not limited to, any Communications regarding matters pending before the Department, including before the Administrative Hearing Bureau. This request seeks records from January 7, 2019 to the present.

The Department concluded its search and provides you with the attached disclosable public records. Please be advised that certain information was withheld, in whole or in part, pursuant to Insurance Code sections 12919 and 735.5. In addition, the Department purposely excluded production of certain attachments to email correspondence related to ongoing litigation against Applied Underwriters because the Department is not a party. Some of the excluded attachments contain personal health information about individuals that are privileged and confidential under Civil Code section 1798.24, evidence Code sections 1040 and 1041 , and Government Code section 6254, subdivisions (a), (c), (d), and (k). Should you wish to receive copies of these attachments, we ask that you contact the parties' counsels, Mr. Phil Walker and/or Mr. Jeff Silver.

Attachments (via

CALIFORNIA DEPARTMENT OF INSURANCE PROTECT•PREVENT•PRESERVE Legal Branch-Government Law Bureau 300 Capitol Mall, 17th Floor, Sacramento, CA 95814 Tel: (916) 492-3486 • Fax: (916) 324-1883 Email: [email protected] De Guzman, Debbie Lynne

From: Jeff Sliver Sent: Thursday, March 28, 2019 5:01 AM To: Han, Donavan;Burch, Bob;Bello, Adeola Cc: Chen, Jing Yi;Sia, Bernadette;Havlck, Ryan;Mathis, Daniel;Relner, Eric;Vang, Ber;Bernard, Susan;Lo, Michelle Subject: RE: Exit Meeting- Applied Underwriters, Inc. Subgroup

Confirming my attendance.

Jeffrey A. Sliver 10805 Old Mill Road Omaha, Nebraska 68154 Telephone: 402-393-1984 Facsimile: 402·393-8558

··---Origlnal Appolntment---- From: Han, Donavan [mailto:[email protected]] Sent: Wednes9ay, March 27, 2019 3:35 PM To: Jeff Sliver; Burch, Bob; Bello, Adeola Cc: Chen, Jing YI; Sia, Bernadette; Havick, Ryan; Mathis, Daniel; Reiner, Eric; Vang, Ber; Bernard, Susan; Lo, Michelle Subject: Exit Meeting- Applied Underwriters, Inc. Subgroup When:. Thursday, March 28, 2019 1:00 PM-3:00 PM (UTC-06:00} Central Time (US & Canada}. Where:

Hi Everyone,

I would like to schedule an exit meeting with the Applied Underwriters, Inc. management team to discuss the results of the Group Financial Examination as of December 31, 2017. The Agenda for this meeting and a Summary of Findings and Recommendations is attached.

Please forward this invite to anyone you think would need to attend.

Thanks,

Donavan Han, CFE Senior Insurance Examiner- Specialist California Department of Insurance . Field Examination Division · ( 41.5) 538-4066 [email protected]'

PRA-2019-00697 GLB000001 1 CONFIDENTIALITY NOTICE: This communication may contain confidential and/or legally privileged information_. It is solely for the use ofthe Intended reclpient(s). Unauthorized Interception, review, use, or disclosure· is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. ffyou are not the intended recipient, please contact the sender and destroy all copies ofthe communtcatio,n. << File: Exit Meeting Agenda.docx >> << File: Exam Findings and Recommendations.pd/ >> << File: IT Findings and Recommendations with Responses.docx >> << File: Letter of Representatlon,pdf >> << File: Subsequent Events Letter.pdf >> <>

PRA-2019-00697 GLB000002 2 De Guzman, Debbie Lynne

From: Jeff Sliver Sent: Wednesday, March 20, 2019 6:54 AM To: Han, Donavan . Subject: Call

Just confirming there is no call today.

Jeffrey A. Sliver 10805 Old Mill Road Omaha, Nebraska 68154 Telephone: 402-393-1984 Facsimile: 402-393-8558

PRA-2019-00697 GLB000003 1 De Guzman, Debbie Lynne

Prom: Jeff Sliver Sent: Wednesday, March 20, 2019 3:35 PM To: Han, Donavan Subject: RE:, Exit Meeting- Applied Underwriters, Inc, Subgroup

Just confirming and it is okay. You have quite a group attending.

Jeffrey A, Sliver 10805 Old MIii Road Omaha, Nebraska 68154 402-393-1984

From: Han, Donavan [mailto:[email protected]] Sent: Wednesday, March 20, 2019 5:30 PM To: Jeff Sliver Subject: RE: EXlt Meeting- Applied Underwriters, Inc. Subgroup

HiJe~

It will be 11 AM PST and 1 PM CST, Will 1hat be ok? Thanks,

Donavan

From: Jeff Silver Sent: Wednesday, March 20, 2019 3:27 PM .To: Han, Donavan ; Burch, Bob ; Bello, Adeola Cc: Chen, Jing Yi ; Sia, Bernadette ; Havick, Ryan ; Mathis, Daniel ; Reiner, Eric ; Vang, Ber Subject: RE: Exit Meeting-Applied Underwriters, Inc. Subgroup

To confirm, the 1:00 p.m. start time is Pacific time.

Jeffrey A. Sliver 10805 Old Mill Road Omaha, Nebraska 68154 402-393-1984

-----Original Appolntment----- From: Han, Donavan fmailto:[email protected] Sent: Wednesday, March 20, 2019 5:19 PM To: Jeff Sliver; Burch, Bob; Bello, Adeola Cc: Chen, Jing YI; Sia, Bernadette; Havick, Ryan; Mathis, Daniel; Reiner, Eric; Vang, Ber Subject: Exit Meeting- Applied Underwriters, Inc. Subgroup PRA-2019-00697 GLB000004 1 When: T - 6:00) Central Time (US & Canada). Where:

Hi Everyone,

I would like to schedule ru1 exit meeting with the Applied Underwriters, Inc. management te8111 to discuss the results of the Gmup Financial Examination as of December 31, 2017. The Agenda for this meeting and a · Summary of Findings 811d Recommendations will be added to this invite shortly before the meeting.

Please forward this invite to 811yone you think would need to attend.

Thanks,

Donavan Han, CFE Senior Insur;,nce Examiner- Specialist Califol'nia Department of Insurance Field Examination Division (415) 538-4066 donavaµ[email protected],gov

CONFIDENTIALITY NOTICE: This communication may contain c01ifidential and/or legally privileged . i,iformation. It Is solely for the use ofthe intended reciptent(s). Unauthorized interception, review, use, or· . disclosure is prohibited and may violate applicable laws including the Electronic Communicatfons Privacy Act. Ifyou are not the intended recipient; please contact the sender and destroy all copies ofthe c'ommuniqation.

PRA-2019-00697 GLB000005 2 De Guzman, Debbie Lynne

From: Jeff Silver Sent: Thursday, June 6, 2019 2:54 PM To: Hein, Patricia;[email protected] Subject: RE: Applied Underwriters/CIC Petition to Suspend Certificate of Authority

Dear Ms. Hein:

Thank you for your letter.

Jeff Silver

Jeffrey A. Silver 10805 Old Mill Road Omaha, Nebraska 68154 402-393-1984

From: Hein, Patricia Sent: Thursday, June 06, 2019 4:50 PM To: [email protected] Cc: Jeff Silver Subject: Applied Underwriters/CIC Petition to Suspend Certificate of Authority

Dear Mr. Walker:

Please see the attached.

Patricia Hein Attorney IV, Government Law Bureau California Department oflnsurance 45 Fremont Street, 21 st Floor San Francisco, CA 94105 Email:[email protected] Phone: (415) 538-4430 Fax: ( 415) 904-5490

CONFIDENTIALITY NOTICE: This communication may contain confidential and/or legally privileged information. It is solely for the use ofthe intended recipient(s). Unauthorized interception, review, use, or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. lfyou are not the intended recipient, please contact the sender and destroy all copies ofthe communication.

PRA-2019-00697 GLB000006 1 De Guzman, Debbie Lynne

From: Hein, Patricia Sent: Thursday, June 6, 2019 2:50 PM To: [email protected] Cc: [email protected] Subject: Applied Underwriters/CIC Petition to Suspend Certificate of Authority Attachments: Response to Phil Walker Re AU.pdf; AUCRA C&D Order.pdf

Dear Mr. Walker:

Please see the attached.

Patricia Hein Attorney IV, Government Law Bureau California Department of Insurance 45 Fremont Street, 21 st Floor San Francisco, CA 94105 Email:[email protected] Phone: (415) 538-4430 Fax: (415) 904-5490

PRA-2019-00697 GLB000007 1 RICARDO LARA CALIFORNIA INSURANCE COMMISSIONER

SENT VIA EMAIL AND U.S. MAIL

June 6, 2019

Phil Neal Walker Law Corporation 250 King Street, Suite 414 San Francisco, CA 94107

SUBJECT: Petition Re: Certificate of Authority of Applied Underwriters' Affiliates

Dear Mr. Walker:

This letter aclmowledges and responds to your emails, in which you request that the California Department of Insurance schedule a hearing to consider revoking or suspending the certificate of authority of Applied Underwriters' affiliates, AUCRA and 'CIC, and request an order for the production of documents. Unfortunately, I was unaware of your emails until recently because they were automatically diverted to my spam email inbox. Please note for the future that the Department does not accept pleadings or service by email.

Title 10 California Code of Regulations section 2509.40, et seq. sets forth the procedure for employers, insurers, rating organizations and other persons to request review by, or an appeal to, the Insurance Commissioner concerning the business of workers' compensation. Indeed, the Administrative Hearing Bureau has adjudicated a number of cases in which employers prevailed in disputes involving AUCRA and CIC's business practices. Although these regulations and related statutory authority provide an adjudicatory process for persons aggrieved by the application ofrate filings, there is no similar process under sections 700(c) and 704. Nonetheless, thank you for notifying the Department of your concerns regarding this insurer. We have also had concerns about the EquityComp product and the behavior of Applied Underwriters and its affiliates.

As you may be aware, in 2016, the Department entered into a Stipulated Consent Cease and Desist Order in which CIC 'and AUCRA agreed to cease and desist issuing new Reinsurance Participation Agreements until such time as the RP A form was submitted tc the WCIRB and the Department in compliance with the requirements of Insurance Code sections 11658 and 11735. A copy of the order is attached. In 2017, in conjunction with the settlement of the appeal of the Shasta Linen case, the Department approved revised forms that CIC and AUCRA agreed to use in lieu of the RPA, and AUCRA agreed to stop using the RPA form in California. The new agreements foster more transparency and accountability and disclose information that employers CALIFORNIA DEPARTMENT OF INSURANCE PROTECT•PREVENT•PRESERVE 45 Fremont Street, 21st Floor PRA-2019-00697 San Francisco, CA94105 GLB000008 Tel: 415-538-4430• Fax: 415-904-5490 [email protected] PHIL NEAL WALKER LAW CORPORATION June 6, 2019 Page2

need to make an informed decision about the EquityComp program. To our knowledge, neither CIC nor AUCRA have writttin any ntJW policies in California sinoo then despite the approval of the revised agreements.

Although we will not be scheduling a hearing regarding this matter at present, we appreciate your alerting us to this situation and we will continue to monitor the activities of CIC and AUCRA in the state to ensure their compliance with California insurance laws.

Cordially, Patricia Jfein

Patricia Hein Acting Assistant Chief Counsel

ph:tms

Attachment

cc: Kristin Rosi, Chief Administrative Law Judge Jeffrey Silver

PRA-2019-00697 GLB000009 Consumer Hotline (800) 927•HELP • Producer Licensing (800) 967-9331 ,-

1 2 3 4 5 BBJlORB THE INSURANCE COMMISSIONER 6 OF 'I'.BE STATE OF CALlFORNIA ·7

8 In the Matter ofthe Certi:fioates of FileNo,: MI-2015-00064 9 A~thorlty. of · QALIFORNJA INSURANCE COMPANY STIPULATED CONSENT CEASE AND 10 and APPLIED UNDERWRITERS DESIST ORDER ~APTIVE lUSK ASSURANCE ll COMPANY, rnc. ' 12 Respondents. 13 !-'--.--..------' 14 . The California Department of Insuranoe (CD)), Respondent California Insurance ·15 Company (CIC) and Respondent Applied Underwriters Captive Risk Assurance Co.lJ.'\P.IIIIY, mo. 16 (AUCRA) enfe!• into this Stipulated Consent Cease and Desist Order (Consent Ordet) and CIC 17 and AUCRA 1 consent to the issuance of this Consent Order by the Insuranoe Commission.er ' ' 18 pursuant to the terms set furth below: 19 I ..

20 MATTERS IN THIS-PROQBEOING 21 A. CIC and AUCRA each acknowledge gervice and receipt of the Notice _of Hearing and 22 Ol·der to Cease and Desist from Issuance ur Renewal of Workers' Comp~slo)tfon )':n,aur8Jlce 23 Policies and Collateral/Ancillary Agt,'eeme:tits :!Ii Violation_ of Insurance Code §§11658 and 11735 24 and California Cod!l of Regulations, Title 10, Sections_ 2251. and 2268 dated Jun!l 28,2016 (the 25 Notice) and acknowledge sel'vice 1111d receipt ofthe Amended Notice of Hearing and-Orderto . . ' 26 Cease 1111d Desist from Issuance or Renewal of Workers' Compensation Irisur1111oe l'olicies and 27 1Nothing In this Coll/lent Order 8hall be oonstruod 11B an llllmillldon by CDI 1hat CIC oud AUCRA are nota Bingle . 28- ontlty fur purposOJI of the Commissioner's Order ln In th~ Mm/er ofthe Appeal qfSh®ta .linen Supply, Inc., CDI':Flle No. AHB·WCA-)4-31.

1 PRA-2019-00697 GLB000010 I Collateral/Anoillru:y Agreements in Violation oflnsut:8ll.Ce Code §§11658 and 11735 and 2 ~alifornia Code ofRegulationii, Title 10, Sections 2251 lllld 2268 dated July 13, 2016 (the 3 AmendedNotice),

4 B. CIC.and AUCRA deny the allegations set.forth in 1he Notice and the Amended Notice 5 but in lieu of proceeding· with a hearing ori the Amended Notice on July 27; 2016, agreB to the ' ' 6 tel'J1ls set forth in this Consent Order., 7 C. The CDI, CIC andAUCRA agree that the ter.tiis of1his Consent Order do ,not constitute an admission or agreement by QIC o~ AUCRA as to malters alleged in the Notice and 8 · the Amended Notice, 9 10 rr 11 RECITALS 12 A. The Notice and Amended Notice' allege th.et CIC issued guaranteed cost workers' 13 compensation Jn.qu:ran~-o !Jolfoies (Guaranteed Cost Polici.e/s) th.et required the employer/insured to 14 enter into a Reinsurance l'articipation Agreem.ent (RPA) with AUCRA: 15 B. The l.n!lqrance Cqmmissioner issued a Decision & Order in/n the Matter ofthe Appeal 16 ofSh

2 PRA-2019-00697 GLB000011 1. m 2 DEFINIDONS 3 · A. ThetermRPAmeans (i) the RP A form issued to Shasta Linen Supply, Inc. thutwas ' ' 4 the subject of the Decision & 01-der in Shasta Linen for whioh the o-urrent term of the RP A has 5 not expired or (ii) any form of RP A that is su~tantlally slml!a.r to the RP A issued t.o Shasta Linen ' 6 Supply, Inc. and that ls ancillary 01· collateral to a guaranteed cost woikers' compensation 7 insurance policy that oovers olaltns by California workers !U'lsing within locations in California 8 and/or employees employed in faoilltie~ in California, or workers whose employment is otherwia~ 9 ooveredunder California workers' compensation laws, regardless ?fwhere CIC and an employer 10 entered the contract for which the_ current tel'l!l of the RP A has not expired; This definition 11 excludes non-California employees tliat are covered by a non-Callfoi:nia workers' compensation 12 policy.

13 B, Th~te1'll). •~olicy'' or Pplicies" means (i) a Guaranteed Cost Policy or Policies fur 14 whichllllRPAis in force as of July 1, 2016 (that is, the current term of the RP Ahas not expired) 15 and (~) Guarim:teed Cost Polici.es that cover claims by California workers, arising within locations H, in California and/or employe~ employed in facilities in Celi:lbrnia or-workei'S whose en;-ployment 17 is otherwise oovered'under California, workers' compens11tion laws, regardless of where CIC and . . . ' 18 an employer o.ntered the contract, for which the RP A expired between the date of the Notice and ' . 19 the date of this COllllent Otder (hereinafter, "Califomia l>olicy"), This definition excludes non- 20 California employees that are covered by a non-Califprnia workel's' compensation p_olicy. 21 IV 22 AGREEMENT 23 . A. CIC and AUCRA will ceruie and desist from issuing new RP As or renewing existing

24. RP As with respect to a California Policy until suoh time 8IJ the RP A has been submitted to the

25 WCIRB and the CDiin compliance with the requirements of Insurance Co.de §11658 and §11735 26 and all other applicable statutes and regulations, and the RP A has not been disappi:oved. 27 B. Notwithstanding Paragraph IV (A) above, CIC may renew a Policy isaued in 28 connection with an RP A in"foroe as of July 1, 2016.

3 PRA-2019-00697 GLB000012 1 C. Arbitrations under either an RP A that is currently an in-force RP A or a past RP A 2 entered into or issued in California will take place in Califomia, 3 D. ClC and AUCRA will not apply run-off loss developmoot factors to any Policy Ell any 4 time, including upon termination, OllllCllllation o:r nonrencwal o:f the RP A or upon tel'minmlon, 5 cancellntion or non.renewal ofth_e Policy, The term ''run-off loss development factor" means the 6 run-off loss development factor referred to in RP A Schedule 1, Paragraph 4. 7 E, CDI actuaries, on the one hand, and CIC and AUCRA actuaries on the ol:lmr hand, will 8 immediately meyt and confer for the purpose of dere)'.llllllUlg and agreeing upon modified loss 9 dewlopment factors (LDF.s) to be used in connection wi1h the Policies. Upon agreement mnong . . 10 the actuaries llll to modified LDFs, which may in.elude the current LDFs, those LDFs will apply to 11 the Policies and RP As, 12 F. If CDI actuaries and CIC and AUCRA actµaries are able to. agi:ee on modified JJ)Fs, ,• 13 IUI referred to in Paragraph (IV) (E), then nc h~aiing wlll be held on the Amen:aed Notice, and this 14 m~tter will be concluded, lfthe CDI aotuari

18 Administmtive Hearing Bureau (AlIB), or llll set by AHB. 19 G. If an agreement ·among actuaries as speaified in Paragraph IV (F) is 11ot rea

4 PRA-2019-00697 GLB000013 1 I. If CIC or AUCRA obtain a preliminary in.junotion In the Wrlt Proceeding on the 2 g!'OUlJ.ds specified in Paragmph IV (H), above, CIC and AUCRA agree to ;111eet and confer with 3 the CDI to determine whother such relief should cause the pal.ties to agree to stay this Con.sent 4 Order pending the outcome of the Writ Petition on the merits. CIC and AUCRA acknowledge 5 that the CDI does not concede that injunctive 1-elief ls an appropriate remedy in the Wrlt 6 Pxoceeding. 7 J, If a fma1judgment of the natul'e specified in Paragraph IV (H) above is entered, CIC ' . 8 and AUCRA nonetheles.s agree that the.amendments to RP As that are specified hi Paragraph 9 IV(C) and·IV(.D) of this Consent Order will remain in force, and (Ii) ifCDI aotuaries'and CIC and · 10 AUCRA acturu:le.s agree upon loss development :factors as provided for in Pl\l'agraph IV(E)

11 below, the agre5'.1 µpon loss development fuoto~s will' continue to apply to atiy RP A

5 PRA-2019-00697 GLB000014 1 M. Nothing in this Consent Order prevenui CIC from issuing standalone Guuranieed Cost 2 Policies that havB been submi~d to the WCJRB and the CDI and which have not been 3 disapproved. The term "standal6n~" means a Guaranteed Cost Policy for which no RP A is 4 entered into. ·5 N.. Nothing in the Consent Order limits or affects fue rights of the Insurance

6 Commissioner in connection with the Writ J>etition 01· Shqsta Linen and, except as otherwise 7 apeoified in Article IV, D, E; F, and J above, no1hing in this Stipulated Agreement a:ffoots·ot· 8 limlts the powers or rights ofthe Instu:m1ce Commissioner to contend or declare that RP All (other 9 than RP As that are filed w.itti the WCIRB and the CDI and that 8:1'e not disapproved) are 10 unenforceable, void, voidable, or illegal and nothing limits the powers ox rights of the Insmanoe 11 Commissioner to initiate or make any investigation, to institute any legal or ll

6 PRA-2019-00697 GLB000015 co~tingent upon the Insurance Commissioner's app1'0va1, which shall be evidenced by the Order 2 in substantially tbe form and content as set forth on page 8 hereof. 3 · The CDI and Respondents CIC and AUCRA execute this Consent Order as follows: 4 Date: .¥-!.$'2016 CALlFORNIA DEPARTMENT OF INSURANCE 5 . 'By: .L ?(,~·- -·- - . . 6 MICHAELJ.L 7 DEPUTY GEN1J:l'.,1M1.11..,OUNSEL 8 9 Date: a~l-4\. f'°'lr, 2016 CALIFORNIA INSURANCE COMPANY 10 11 12 13 14 15 16 17 Date; A~tf.2016 APPLIED UNDERWRITERS CAPTIVE RISK ASSURANCE COMPANY, INC, 18 19 29 . 21 22 23 24 25 26 27 28

.,) 7 PRA-2019-00697 GLB000016 1 (PROPOSED] ORDER ADOPTING STIPULATED CONSENT CEASE AND DESIST ORDER 2

3 4 GOOD CAUSE HAVING BEEN SHOWN, California Insurance Commissioner Dave 5 Jones hereby adopts the Stipulated Consent Cease and Desist Order set forth on pages 1 through 7 6 of this document, and hereby orders that the parties comply with the tenns and conditions to 7 which they have agreed.

8

9 Date: September£., 2016 10 11 12 13 14 15 16 17

18 19 20 21

22 23 24 25 26

27 28

PRA-2019-00697 GLB000017 8 De Guzman, Debbie Lynne

From: Jeff Silver Sent: Thursday, June 6, 2019 2:54 PM To: Hein, Patricia;[email protected] Subject: RE: Applied Underwriters/CIC Petition to Suspend Certificate of Authority

Dear Ms. Hein:

Thank you for your letter.

Jeff Silver

Jeffrey A. Silver 10805 Old Mill Road Omaha, Nebraska 68154 402-393-1984

From: Hein, Patricia Sent: Thursday, June 06, 2019 4:50 PM To: [email protected] Cc: Jeff Silver Subject: Applied Underwriters/CIC Petition to Suspend Certificate of Authority

Dear Mr. Walker:

Please see the attached.

Patricia Hein Attorney IV, Government Law Bureau California Department of Insurance 45 Fremont Street, 21st Floor San Francisco, CA 94105 Email:[email protected] Phone: (415) 538-4430 Fax: (415) 904-5490

CONFIDENTIALITY NOTICE: This communication may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use, or disclosure is prohibited and may violate applicable laws· including the Electronic Communications Privacy Act. Ifyou are not the intended recipient, please contact the sender and destroy all copies of the communication.

PRA-2019-00697 GLB000018

1 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Sunday, May 26, 2019 5:31 PM To: Hein, Patricia Cc: Jeff Silver Subject: Applied Underwriters/Calif. Ins. Co: Pet. to Suspend Certif of Authority. Exh 9 of 9 Attachments: 4 Pet to Susp Exh 9 052619.pdf

Attached.

Phil Walker

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000019 1 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Sunday, May 26, 2019 5:31 PM To: Hein, Patricia Cc: Jeff Silver Subject: Applied Underwriters/Calif. Ins. Co: Pet. to Suspend Certif of Authority. Exh 8 of 9 Attachments: 4 Pet to Susp Exh 8 052619.pdf

Attached.

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000020 1 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Sunday, May 26, 2019 S:31 PM To: Hein, Patricia Cc: Jeff Silver Subject: Applied Underwriters/Calif. Ins. Co: Pet. to Suspend Certif of Authority. Exh 7 of 9 Attachments: 4 Pet to Susp Exh 7e 052619.pdf; 4 Pet to Susp Exh 7d 052619.pdf; 4 Pet to Susp Exh 7c 052619.pdf; 4 Pet to Susp Exh 7b 052619.pdf; 4 Pet to Susp Exh 7a 052619.pdf

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000021 1 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Sunday, May 26, 2019 5:30 PM To: Hein, Patricia;Jeff Silver Subject: Applied Underwriters/Calif. Ins. Co: Pet. to Suspend Certif of Authority. Exh 6 of 9 Attachments: 4 Pet to Susp Exh 6a 052619.pdf; 4 Pet to Susp Exh 6b 052619.pdf

Attached.

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816°3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000022 1 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Sunday, May 26, 2019 5:28 PM To: Hein, Patricia Cc: Jeff Silver Subject: Applied Underwriters/Calif. Ins. Co: Pet. to Suspend Certif of Authority. Exh 3 of 9 Attachments: 4 Pet to Susp Exh 3a Revd 052619.pdf

Attached.

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000023 1 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Sunday, May 26, 2019 5:29 PM To: Hein, Patricia Cc: Jeff Silver Subject: Applied Underwriters/Calif. Ins. Co: Pet. to Suspend Certif of Authority, Exh 4 and 5 of 9 Attachments: 4 Pet to Susp Exh 4 052619.pdf; 4 Pet to Susp Exh 5 052619.pdf

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000024 1 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Sunday, May 26, 2019 5:27 PM To: Hein, Patricia;Jeff Silver Subject: Applied Underwriters/Calif. Ins. Co: Pet. to Suspend Certif of Authority. Exh 1 and 2 of 9 Attachments: 4 Pet to Susp Exh 1 052619.pdf; 4 Pet to Susp Exh 2a Revd 052619.pdf

Attached.

Phil Walker Counsel for Pitamber, Stovall's Inn, Personal Touch Clean., and Envir. Control

Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000025 1 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Friday, May 24, 2019 11 :18 AM To: Hein, Patricia Cc: Jeff Silver;[email protected];[email protected] Subject: Stovall's Inn, Personal Touch Cleaning, and Envir. Control: Date for Taking Action re Further Steps of 5/31 /19

Dear Ms. Hein:

I have previously filed Requests for Order Compelling Production in these matters.

I will take further action regarding this matter on June 1, 2019, if a determination is not received with regard to these Requests.

I do this because I have had experience before where the Department of Insurance has not acted on requests. In such situations, the Department never responded after filings and response. Therefore, I have to implement a date on which to act because I do not !mow if I will receive a response or determination from the Department.

Respectfully submitted,

Phil Walker

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000026 1 De Guzman, Debbie Lynne

From: Phil Neal Walker < [email protected]> Sent: Friday, May 17, 2019 11:51 AM To: Hein, Patricia Cc: Jeff Silver Subject: Applied Underwriters, et. al. Petition for Hrg. on Suspension, Denial, or Revocation of Certificate to Insure of Applied entities Attachments: AU Req for Hrg On Susp of Certif of Auth to Insure 051719.docx

Dear Ms. Hein:

Attached, please find a Request for Hearing on Suspension, Denial, or Revocation of the Certificate to Insure of the Applied entities.

In light of the pending sale of the Applied entities by September 30, 2019, we do respectfully request the scheduling of the hearing at the earliest possible date.

Exhibits will follow.

I am also filing 2 copies with the Department of Insurance Administrate Hearing Bureau.

Respectfully submitted,

Phil Walker Counsel for Pitamber, Stovall's Inn, Personal Touch Cleaning, and Environment Control.

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000027 1 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Monday, May 13, 201911:13 AM To: Jeff Silver Cc: Hein, Patricia Subject: Re: Environment Control Building Maintenance Company

Dear Ms. Hein,

I am sure you are familiar with the corporate structure of the Applied companies, including Applied Underwriters, Inc., AUCRA, California Insurance Company, Continental Indemnity, Applied Risk Services, and others.

I. The corporate structure is outlined in the Shasta Linen ALJ Dept. ofInsurance decision.

2. Tribunals which have examined the corporate relationships have found that all of the Applied companies are intertwined and inextricable and should be treated as one entity.

3. Environment Control renews each of its arguments made to the Department oflnsurance.

4. Compliance with Labor Code Section 3762 and Insurance Code Sec. 700(c) by the Applied companies is independent of any arbitration action. As a result, Environment Control requests that the Department of Insurance exercise its authority over the Applied companies and order them to comply with Labor Code Section 3762.

Respectfully submitted,

Phil Walker Counsel for Environment Control

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000028 1 On Mon, May 13, 2019 at 7:52 AM Jeff Silver wrote: i Ms. Hein:

I am in receipt of Mr. Walker's May 8, 2019 e-mail to you again urging the California Department of Insurance to become involved as leverage in a matter pending in a private arbitration.

This is amply demonstrated by Mr. Walker's reference to AUCRA (Applied Underwriters Captive Risk Assurance Company, Inc.). AUCRA is not Environment Control Building Maintenance company's workers' compensation insurer and is not therefore subject to Labor Code Section 3762.

As previously indicated, this dispute will be resolved in the existing pending private arbitration.

Thank you for your attention to this matter.

Jeff Silver

Jeffrey A. Silver

10805 Old Mill Road

Omaha, Nebraska 68154

Telephone: 402-393-1984

Facsimile: 402-393-8558

PRA-2019-00697 GLB000029 2 De Guzman, Debbie Lynne

From: Jeff Silver Sent: Monday, May 13, 2019 7:52 AM To: Hein, Patricia Cc: '[email protected]' Subject: Environment Control Building Maintenance Company

Ms. Hein:

I am in receipt of Mr. Walker's May 8, 2019 e-mail to you again urging the California Department of Insurance to become involved as leverage in a matter pending in a private arbitration.

This is amply demonstrated by Mr. Walker's reference to AUCRA {Applied Underwriters Captive Risk Assurance Company, Inc.). AUCRA is not Environment Control Building Maintenance company's workers' compensation insurer and is not therefore subject to Labor Code Section 3762.

As previously indicated, this dispute will be resolved in the existing pending private arbitration.

Thank you for your attention to this matter.

Jeff Silver

Jeffrey A. Silver 10805 Old Mill Road Omaha, Nebraska 68154 Telephone: 402-393-1984 Facsimile: 402-393-8558

PRA-2019-00697 GLB000030 1 De Guzman, Debbie Lynne

From: Jeff Silver Sent: Tuesday, May 7, 2019 8:15 AM To: Hein, Patricia Cc: [email protected] Subject: Environment Control Building Maintenance Company Attachments: P Hein.pdf; Ex 1 EC.pdf; Ex 2 EC.pdf; Ex 3 EC.pdf

Ms. Hein:

Please see attached response.

Thank you.

Jeff Silver

Jeffrey A. Silver 10805 Old Mill Road Omaha, Nebraska 68154 Telephone: 402-393-1984 Facsimile: 402-393-8558

PRA-2019-00697 GLB000031 1 California Insurance Company P.O. 130X3646 6) OMAHA, NE 66103-0646

Wrller's Direct Line 402-342-4900 oxt. 4141; Facsimile 402-393-8558 E-MAIL: feffrmilver@sl/ver-taw,net

May7,2019

Via Eledronlc Mail

Patricia Hein California Department oflnsurance Legal Division 45 Fremont Street 23rd Floor San Francisco, California 94105

RE: Environment Control Building Maintenance Company, Inc.

Dear Ms. Hein:

This correspondence will respond to Phil Walker's proposed Order sent to you on May 6, 2019 in connection with Environment Control Building Maintenance Company, Inc. ("Environment Control") and his claim that documents responsive to Labor Code §3762 are not being provided.

Mr. Walker claims this is the fourth request being made to you. To that extent, Mr. Walker is con·ect. The first is Garratt Callahan. This request was in connection with a pending arbitration with the request for claims information preceding the arbitration and thus seeking pre- arbitration discovery, That matter was resolved by payment by Garratt Callahan.

The same situation existed with respect to Stovall' s lim which I responded to by April 29, 2019 e-mail correspondence to you.

The pattern continued with respect to Personal Touch to which I responded on May 2, 2019.

There arc two separate responses to Mr. Walker's correspondence which are detailed below.

First, Environment Control's recent monthly Plan Analysis from Applied Underwriters, Inc. provides a detailed listing of c¥ery workers' compensation claim of Environment Control's injured workers. The two most recent Plan Analyses are attached. As you can see, on Page 6 of the February, 2019 Plan Analysis (Exhibit I), each claim is identified by date of injury, status

PRA-2019-00697 GLB000032 Patricia Hein May 7,2019 Page2

and total incurred. On Page 12 of the Plan Analysis it provides a Summary of Claims. On Page 13, an Analysis of Closed Indemnity Claim Counts, Claims Summary by Accident Cause, and on Page 14 Claims Summary by Body Part Injured and Claims Summary by Nature oflnjury. Finally, beginning on Page 15, there is a Claims Listing by name of claimant, status, accident description, date reported, expense type and incurred and total paid. I have highlighted these identified pages. The same Plan Analysis with similar data for the period of March 1, 2019 through March 31, 2019 is provided (Exhibit 2). By simply comparing the Plan Analyses, Personal Touch can determine what changes in the claims have occurred, as well as whether individual reserve amounts have decreased, remained the same or increased, and amounts paid.

The foregoing provided Enviromnent Control with the required information while at the same protecting the individual private medical information of each claimant..

On April 27, 2019, Mr. Walker filed a Demand For Arbitration with JAMS and in that same correspondence made a demand for claim files to be produced on May 4, 2019, a copy of which correspondence is attached hereto as Exhibit 3. Claim No. 3 of the Arbitration asserts Breach of Contract- Improper Claims Handling. Claim No. 4 of the Arbitration asserts Negligent Claims Handing, Claim No. 5 asserts Gross Negligence in Claims Handing, Claim No. 6 asserts Negligent Hiring, Supervision, and Retention of Employer Handling Claimant Workers' Compensation Claims. Clearly, Mr. Walker is requesting copies of claim files not for Labor Code §3762 but to do pre-arbitration discovery to support Environment Control's arbitration claims. This despite arbitrations being confidential.

California Insurance Company respectfully suggests this is now a private litigation matter and the California Department of Insurance should allow the matter to be fully litigated in the arbitration and not become otherwise involved.

Thank you for your attention to this matter.

Very truly yours,

A. SILVER Secretary and General Counsel

JAS/ld Attachment

CC: File

PRA-2019-00697 GLB000033 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Monday, May 6, 2019 3:26 PM To: Hein, Patricia Cc: Jeff Silver Subject: Applied Underwriters: Fourth Request to Ins. Commissioner for Order of Production per LC Sec. 3762 Attachments: ARB Envir Control Req for Oto Compel Prodn to Cal Ins Comm 050619.docx

Dear Ms. Hein:

Attached, please find a Request for Order of Production filed on behalf of California insured Environment Control.

This now makes the fourth time I have had to seek the assistance of the Insurance Commissioner due to Applied Underwriter's and it affiliates and subsidiaries', failure to comply with discovery requests under Labor Code Section 3762. ·

Respectfully submitted,

Phil Walker Counsel for Environment Control

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000034 1 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Saturday, May 4, 2019 10:43 AM To: Hein, Patricia;Jeff Silver Subject: Pers. Touch Cleaning v Applied Underwriters: Forwarded to you May 3, 2019, by email

Dear Ms. Hein:

Mr. Silver has written you indicating that it is a private arbitration matter and that the Department of Insurance should not be involved.

I believe he is incorrect. This matter involves enforcement of California Insurance and Labor Code provisions which are applicable to Applied.

1. Labor Code Section 3762 requires an insurer to provide non-privileged documents which affect the insured's premium to the insured. I wrote Mr. Silver requesting this information which has not been provided. Therefore, Applied and its affiliates and subsidiaries, including California Insurance Company, are in violation of Labor Code Section 3762.

2. Cal. Ins. Code Sec. 700 (c) provides:

{c}

After the issuance of a certificate of authority, the holder shall continue to comply with the requirements as to its business set forth in this code and in the other laws of this state...

By refusing to comply with Labor Code Section 3762, Applied Underwriters and its affiliates and subsidiaries are in violation of California Insurance Code Section 700(c).

Therefore, I request that the applicable Certificate of Authority be suspended until Applied, et. al., demonstrate compliance with Insurance Code Sec. 700(c) and Labor Code Section 3762.

Respectfully submitted,

Phil Walker Counsel for Personal Touch Cleaning & Maintenance Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected] GLB000035 1 Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000036 2 De Guzman, Debbie Lynne

From: Phil Neal Walker < [email protected]> Sent: Friday, May 3, 2019 3:47 PM To: Hein, Patricia Cc: Jeff Silver Subject: Personal Touch Cleaning v Applied: Response to Mr. Silver's letter to you of May 2, 2019

Dear Ms. Hein:

I wrote you forwarding a Request for Order of Production from the Insurance Commissioner to Applied Underwriters.

1. Mr. Silver has now responded on May 2, 2019. Unfortunately, his response is both inaccurate and not truthful.

2. I have requested the following information pursuant to Labor Code Section 3762 which has not been provided. This is not pre-arbitration discovery. It is a request for records under California Labor Code Section 3762. Arbitration has now been commenced.

I have not received the following records requested on the specified claim files: a. All claim notes b. All reserve calculations c. All reserve listings d. Full payment record e. Written records lfthe approval by AUCRA of all parents of$15,000 or more f. Written records of approval of AMCRA of all reserve increases of $50,000 or more; and g. Written records indicating AUCRA's approval of claims handling as reasonably acceptable and written confirmation of such.

3. The Plan Analysis he provided does not include these requested documents.

4. I have never sought private medical information of claimants.

5. Mr. Silver wants the Department of Insurance to stay out of this matter. I believe the Department has a duty under the Insurance Code to ensure the California authorized insurers comply with California law, particularly Labor Code Sec. 3762, which is a requirement for continuing to be Certified as Authorized to Conduct Insurance Business in California.

6. Therefore,PRA-2019-00697 Personal Touch Cleaning requests that the Order to Compel Production issue. GLB000037 1 Respectfully submitted,

Phil Walker Counsel for Personal Touch Cleaning

Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

. Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000038 2 De Guzman, Debbie Lynne

From: Jeff Silver Sent: Friday, May 3, 2019 7:07 PM To: Hein, Patricia Cc: 'Phil Neal Walker' Subject: RE: Personal Touch Cleaning & Maintenance, Inc. -- Applied Underwriters, Inc.

It does not relate to any pending case except a pending private arbitration between the parties. I simply responded to Mr. Walker's effort to involve the Department in a private arbitration matter.

Jeff Silver

From: Hein, Patricia [mailto:[email protected]] Sent: Friday, May 3, 2019 6:05 PM To: Jeff Silver Cc: 'Phil Neal Walker' Subject: RE: Personal Touch Cleaning & Maintenance, Inc. -- Applied Underwriters, Inc.

Mr. Silva.

I am not familiar with this matter. Please let me know if this relates to a pending case or some other issue.

Thank you.

Patricia Hein Acting Assistant Chief Counsel, Government Law Bureau California Department of Insurance 45 Fremont Street, 21st Floor San Francisco, CA 94105 Email:[email protected] Phone: (415) 538-4430 Fax: (415) 904-5490

From: Jeff Silver [mailto:[email protected]] Sent: Thursday, May 2, 2019 2:30 PM To: Hein, Patricia Cc: 'Phil Neal Walker' Subject: Personal Touch Cleaning & Maintenance, Inc. --Applied Underwriters, Inc.

Please see attached correspondence.

Jeffrey A. PRA-2019-00697Silver GLB000039 1 10805 Old Mill Road Omaha, Nebraska 68154 Telephone: 402-393-1984 Facsimile: 402-393-8558

PRA-2019-00697 GLB000040 2 De Guzman, Debbie Lynne

From: Jeff Silver Sent: Thursday, May 2, 2019 2:30 PM To: Hein, Patricia Cc: 'Phil Neal Walker' Subject: Personal Touch Cleaning & Maintenance, Inc. -- Applied Underwriters, Inc. Attachments: P Hein Personal Touch.pdf

Please see attached correspondence.

Jeffrey A. Silver 10805 Old Mill Road Omaha, Nebraska 68154 Telephone: 402-393-1984 Facsimile: 402-393-8558

PRA-2019-00697 GLB000041 1 Califr,rnta Insurance Company P.O. BOX 3646 OMAHA, NE 68103-0646

- Writer's Direct Lino 402-342-4900 axt, 4141; Facslmllo 402-393-9558 E-1'1/AIL: /[email protected]

May 2, 2019

Via Electronic Mail

Patricia Hein California Department of Insurance Legal Division 45 Fremont Street 23rd Floor San Francisco, California 94105

RE: Personal Touch Cleaning & Maintenance, Inc,

Dear Ms. Hein:

This correspondence will respond to Phil Walker's May 1, 2019 correspondence on ·behalf of Personal Touch Cleaning & Maintenance, Inc. ("Personal Touch") and his claim that documents responsive to Labor Code §3762 are not being provided.

Mr. Walker identified three entities for which he has requested claims information. The first is Garratt Callahan. This request was in connection with a pending arbitration with the eequest for claims information preceding the arbitration and thus seeking pre-arbitration discovery. 11-iat matter was resolved by payment by Garratt Callahan.

The same situation exists with respect to Stovall's Inn which I responded to by April 29, 2019 e-mail correspondence to you.

The pattern continues with respect to Personal Touch. There are two separate responses to Mr. Walker's correspondence which are detailed below.

First, Personal Touch's recent monthly Plan Analysis from Applied Underwriters, Inc. provides a detailed listing of every workers' compensation claim of Personal Touch's injured workers. The two most recent Plan Analyses are attached. As you can see, on Page 4 of the February, 2019 Plan Analysis (Exhibit 1), each claim is identified by date of injury, status and total incurred. On Page 6 of the Plan Analysis it provides a Summary of Claims. On Page 7, an Analysis of Closed Indemnity Claim Counts (Page 8), Claims Summary by Accident Cause (Page 8), and on Page 9 Claims Summary by Body Part Injured and Claims Summary by Nature of Injury. Finally, begim1ing on Page 10, there is a Claims Listing by name of claimant, status,

PRA-2019-00697 GLB000042 Patricia Hein May 2, 2019 Page2

accident description, date reported, expense type and incurred and total paid. I have highlighted these identified pages. The same Plan Analysis with similar data for the period of March 1, 2019 through March 31, 2019 is provided (Exhibit 2). By simply comparing the Plan Analyses, Personal Touch can determine what changes in the claims have occurred, as well as whether individual reserve amounts have decreased, remained the same or increased, and amounts paid.

The foregoing provided Personal Touch with the required information while at the same protecting the individual private medical info1mation of each claimant.

On April 17, 2019, Mr. Walker filed a Demand For Arbitration with JAMS and in that same correspondence made a demand for claim files to be produced on April 24, 2019, a copy of which correspondence is attached hereto as Exhibit 3. Claim No. 3 of the Arbitration asserts Breach of Contract - Improper Claims Handling. Claim No. 4 of the Arbitration asserts Negligent Claims Handing, Claim No. 5 asserts Gross Negligence in Claims Handing, Claim No. 6 asserts Negligent Hiring, Supervision, and Retention of Employer Handling Claimant Workers' Compensation Claims. Clearly, Mr. Walker is requesting copies of claim files not for Labor Code §3762 but to do pre-arbitration discovery to support Personal Touch's arbitration claims. This despite arbitrations being confidential.

California Insurance Company respectfully suggests this is now a private litigation matter and the California Department of Insurance should allow the matter to be fully litigated in the arbitration and not become otherwise involved.

Thank you for your attention to this matter.

,~JEFF,REY A. SIL VER Soorfotary and General Counsel ✓ JAS/ld Attachment

CC: File

PRA-2019-00697 GLB000043 De Guzman, Debbie Lynne

From: Hein, Patricia Sent: Monday, May 13, 2019 11 :45 AM To: Yim, Brentley Subject: FW: Personal Touch Cleaning v Applied: Third Employer I have had to file a Request for Order of Production for. Attached.

Follow Up Flag: Follow up Flag Status: Completed

-----Original Message----- From: Phil Neal Walker [mailto:[email protected]] Sent: Wednesday, May 01, 2019 1:58 PM To: Hein, Patricia Cc: Jeff Silver Subject: Personal Touch Cleaning v Applied: Third Employer I have had to file a Request for Order of Production for. Attached.

Dear Ms. Hein,

This constitutes the third Request for Production I have filed with the California Insurance Commissioner in light of the failure of Applied Underwriters and its affiliates and subsidiaries to comply with California law, specifically Labor Code Section 3762.

The first employer was Garratt Callahan. That Request was filed with Ins. Commissioner Jones. After the filing of the Request, Applied produced the requested information.

I filed a second Request on behalf of Stovall's Inn. That Request was filed on April 27, 2019.

Attached, please find the Third Request filed on May 1, 2019, on behalf of Personal Touch Cleaning.

I would request a ruling by the Insurance Commissioner on this Request.

I anticipate there will be further Requests on behalf of additional employers. I anticipate a fourth Request to be filed in the week of May 6, 2019.

Respectfully submitted,

Phil Walker Counsel for Personal Touch Cleaning

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected] GLB000044 1 Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000045 2 De Guzman, Debbie Lynne

From: Hein, Patricia Sent: Monday, May 13, 2019 11 :45 AM To: Yim, Brentley Subject: FW: Stovall's Inn v Applied U Req. for Order of Ins. Comm Compelling Applied to Comply with California Law

Follow Up Flag: Follow up Flag Status: Completed

-----Original Message----- From: Phil Neal Walker [mailto:[email protected]] Sent: Wednesday, May 01, 2019 12:33 PM To: Hein, Patricia Cc: Jeff Silver Subject: Stovall's Inn v Applied U Req. for Order of Ins. Comm Compelling Applied to Comply with California Law

Dear Ms. Hein,

I have received Mr. Silver's response to my Request for Order Compelling Production filed on April 27, 2019.

1. I noted that my request for claims file information was under Labor Code Section 3762. Mr. Silver attempts to mislead you that ii was part of an arbitration. II was not. Labor Code Section 3762 requires an insurer to provide all information requested by an insured which may affect the insureds premium. a. As part of that, I requested the claimant notes, reserve calculations, reserve listings, and full payment records. This is because the premium is calculated based on amounts paid out+ reserves. Therefore, the claim notes indicate whether or not the payments made were correct under California law as does the payment record. The reserve calculations and reserve listings indicate whether or not the reserves were correct under California law. b. Stovall's Inn had purchased the EquityComp program with which you are familiar. That plan was described as a loss-sensitive retrospective rating plan where the employer's losses and experience would affect the premium charged.

In various proceedings, Applied now claims this was not a loss sensitive retrospective rating plan but, rather, a guaranteed cost policy accompanied by a profit-sharing plan. That is NOT what any California DOI ALJ has found in either Shasta Linen or Platinum Security. c. Mr. Silver has never provided the requested information. Instead, he offered "Claim Summaries" (1 to 2 page summaries prepared by the Claims Examiners" and redacted medical reports. As you can see, this is not what I requested.

Alternatively, he indicated that I could fly to Omaha to review the claim files.

3. Labor Code Section 3762 makes no provision for an insured's representative to have to travel to Omaha to secure claims information. Further, as you can see, a claim summary and redacted medical information would provide no information on whether or not the payments made were correct legally or the reserves set were correct legally.PRA-2019-00697 GLB000046 1 4. I detailed the language of California Labor Code Section 3762 on pp. 2 and 3 of my Request for Order of Production. Mr. Silver has failed to address the requirements of that statute.

5. Further, as noted, Applied Underwriters and all of its affiliates and subsidiaries licensed to do business in California must comply with California law in order to maintain a Certificate of Authority. This violation of Labor Code Section 3762 constitutes a breach of that requirement.

Therefore, I renew my request that the Order for Production Issue.

Respectfully submitted,

Phil Walker Counsel for Stovall's Inn

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

Phone: 415-816-3527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000047 2 De Guzman, Debbie Lynne

From: Jeff Silver Sent: Monday, April 29, 2019 2:34 PM To: Hein, Patricia Cc: Phil Neal Walker Subject: Stovall Inns v. Applied Underwriters, Inc. Attachments: FI-L9TFB6Ll41 B004292019162919001.pdf

Please see attached.

Jeffrey A. Silver 10805 Old Mill Road Omaha, Nebraska 68154 Telephone: 402-393-1984 Facsimile: 402-393-8558

PRA-2019-00697 GLB000048 1 California Insurance Company P.O. BOX 3646 OMAfiA, NE 68103-0646

- Writer'• Direct Uno 402'342-4900 ext. 4141; Fac•lmile 402-393-8558 E-MAIi.: lefftpys/lyer@sllver-law."J!I

April 29, 2019

Via Electronic Mail

Patricia Hein California Department of Insurance Legal Division 45 Fremont Street 23rd Floor San Francisco, California 94105

RE: Stovall Inns

Dear Ms. Hein:

This correspondence will respond to Phil Walker's April 27, 2019 correspondence on behalf of Stovall Inns ("Stovall") and his claim that documents responsive to Labor Code §3762 are not being provided.

There are two separate responses to Mr. Walker's correspondence which are detailed below.

First, Stovall's recent monthly Plan Analysis from Applied Underwriters, Inc. provides a detailed listing of every workers' compensation claim ofStovall's injured workers. The two most recent Plan Analyses are attached. As you can see, on Page 5 ofthe February, 2019 Plan Analysis (Exhibit 1), each claim is identified by date of injury, status and total incurred. On Page 8 of the Plan Analysis, it provides a Summary of Claims. On Page 9, an Analysis of Closed Indemnity Claim Counts, Claims Summary by Accident Clause, and on Page 10 Claims Summary by Body Part Injured and Claims Summary by Nature of Injury. Finally, beginning on Page 11, there is a Claims Listing by name of claimant, status, accident description, date reported, expense type and incurred and total paid. I have highlighted these identified pages. The same Plan Analysis with similar data for the period of March I, 2019 through March 31, 2019 is provided (Exhibit 2). By simply comparing the Plan Analyses, Stovall can detennine what changes in the claims have occurred, as well as whether individual reserve amounts have decreased, remained the same or increased, and amounts paid.

The foregoing provided Stovall with the required information while at the same protecting the individual private medical information of each claimant.

PRA-2019-00697 GLB000049 On December 14, 2018, Mr. Walker via correspondence indicated that Stovall was initiating arbitration and in addition to claim files wanted to interview the claims e=iners and supervisors. This was clearly pre-arbitration discovery. See Exhibit 3.

As a result, I viewed Mr. Walker's demand for claim files as essentially pre-arbitration discovery. On February 6, 2019, I offered Mr. Walker that we would make copies of all claim summaries, medical reports with personal medical data redacted and all reserve changes which would provide information consistent with Labor Code §3762 or come to Omaha to view the claim files. The information as to the claims adjusters was not within the purview of Labor Code §3762. Mr. Walker did not accept that option.

On April 17, 2019, Mr. Walker did in fact file a Demand For Arbitration with JAMS. Claim No. 4 of the Arbitration asserts Negligent Claims Handing, Claim No. 5 asserts Gross Negligence in Claims Handing, Claim No. 6 asserts Negligent Hiring, Supervision, and Retention of Employer Handling Claimant Workers' Compensation Claims. Clearly, Mr. Walker is requesting copies of claim files not for Labor Code §3762 but to do pre-arbitration discovery to support Stovall's arbitration claims. This despite arbitrations being confidential.

California Insurance Company respectfully suggests this is now a private litigation matter and the California Department of Insurance should allow the matter to be fully litigated in the arbitration and not become otherwise involved.

Thank you for your attention to this matter.

Very truly yours, V ~,·11,.,""'y A. SIL VER tary and General Counsel

JAS/ld Attachment

CC: File

PRA-2019-00697 GLB000050 De Guzman, Debbie Lynne

From: Phil Neal Walker Sent: Saturday, April 27, 2019 4:51 PM To: Hein, Patricia Cc: Jeff Silver Subject: Stovall's Inn v Applied U: Request for Order of Insurance Comm. Compelling Prodn. Per Lab. Code Sec. 3762 Attachments: ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719 11 Jpeg; ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719 7 Jpeg; ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719 BJ peg; ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719 1OJ peg; ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719 9Jpeg; ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719 6Jpeg; ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719 5Jpeg; ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719 3Jpeg; ARB Stoval ls Inn Exhs to Mot to Compel Prodn 042719 2Jpeg; ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719 4.jpeg; ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719 1Jpeg; ARB Stovalls Inn Exhs to Mot to Compel Prodn 042719Jpeg; CAS Stovall's Inn v AU Pet for Prodn and Not of Intent 042719.docx

Dear Ms. Hein,

As Chief Counsel for Workers Compensation within the Department of Insurance, I am forwarding the attached Request for Order Compelling Production of Documents per California Labor Code Section 3762.

I request that this be considered by the Commissioner.

Applied Underwriters and its affiliates and subsidiaries continue to fail to produce documents requested under Labor Code Section 3762. As a result, Applied Underwriters and its affiliates and subsidiaries are in violation ofinsurance Code Section 700(c) which requires them to comply with all laws of California to continue holding a Certificate of Authority to Insure.

I have attached a Proposed Order.

If you are not the appropriate person to receive this, please pass it on to the individual who is.

Thank you.

Respectfully submitted,

Phil Walker Counsel for Stovall's Inn

Phil Walker Phil Walker, Esq. 250 King Street, Suite 414 San Francisco, CA 94107

PRA-2019-00697 GLB000051 1 Phone: 415-816-3 527 (phone or text) Fax: 888.563.9444 [email protected]

Phil Walker Work Comp Savings Phil Walker AMA Report Reviews www.philwalker.do

PRA-2019-00697 GLB000052 2

EXHIBIT 11

September 17, 2019

VIA EMAIL AND OVERNIGHT DELIVERY

Chao Lor California Department of Insurance 300 Capitol Mall, Suite 1700 Sacramento, CA 95814 Email: [email protected] Tel.: (916) 492-3207

RE: Public Records Act Requests – PRA-2019-00555 and PRA-2019-00697

Dear Ms. Lor,

The Public Records Act (“PRA”) provides that “every person has a right to inspect any public record, except as hereafter provided.” (Gov. Code § 6253(a).) Hence, “all public records are subject to disclosure unless the Legislature has expressly provided to the contrary.” (Williams v. Superior Court (1993) 5 Cal.4th 337, 356.) Moreover, the preamble of the PRA statute notes that “access to information concerning the conduct of the people’s business is a fundamental and necessary right of every person in this state.” (Gov. Code § 6250; ACLU Foundation v. Deukmejian (1982) 32 Cal.3d 440, 447.)

On September 4, September 13, and September 16 the Department provided partial productions of records responsive to Consumer Watchdog’s requests for Commissioner Lara’s calendar of meetings (“Conferences”) and certain Communications, as defined in the above-captioned PRA requests. Disclosure of such public records in full is essential to restoring the public trust in the Office of the Insurance Commissioner in the wake of news reports of influence peddling involving Commissioner Lara and insurance companies regulated by the Department.

In letters accompanying all three productions, the Department stated, without support, that certain responsive records were withheld because they were either privileged or otherwise exempt from disclosure. For example, regarding the calendar entries provided on September 13, on many days there are no entries of meetings whatsoever, suggesting those records have been heavily expurgated and do not reveal the full picture of Commissioner Lara’s Conferences and Communications relevant to the reports of influence peddling.

September 17, 2019 Page 2 of 2

As the Department did not provide any basis for these blanket claims of privilege nor any description of the withheld records, there is no basis for Consumer Watchdog, or a court, to test the claimed privileges. We therefore write to request the Department provide a privilege log containing a summary description of the subject matter of each withheld record, the date of the record, the author and recipient (if any) of the record, and the basis of the claimed privilege or exemption.

Respectfully submitted,

Jerry Flanagan Litigation Director (310) 392-2632

EXHIBIT 12

RICARDO LARA CALIFORNIA INSURANCE COMMISSIONER

September 27, 2019

VIA EMAIL ONLY

Jerry Flanagan Consumer Watchdog 6330 San Vicente Blvd., Suite 250 Los Angeles, CA 90048

RE: Public Records Act Requests - PRA-2019-00555 and PRA-2019-00697

Dear Mr. Flanagan:

This letter is in response to your letter dated September 17, 2019, wherein you requested that the California Department of Insurance ("COi") provide you with a privilege log for all records withheld relating to the above referenced Public Records Act ("PRA") requests.

Please be advised that the COi will not provide you with a privilege log as it is not required to do so under the California Public Records Act. The COi receives between 80-100 PRA requests per month. Any given request could require a review of thousands of records exempt from disclosure. In short, we respectfully decline your request based on the California Supreme Court's analysis in Haynie v. Superior Court of Los Angeles (2001) 26 Cal.4th 1061.

The COi has complied with the requirements under Government Code section 6253, subdivisions (a) and (b) by providing you with all disclosable public records on September 4, September 13, and September 16 in response to your PRA requests. For many of the records produced, COi staff redacted only those portions that are confidential and exempt from disclosure. In each of the letters accompanying all three productions, the COi provided you with a list of exemptions and/or privileges for information redacted or records withheld in its entirety.

Thank you in advance for your courtesy and consideration. m-- Chao Lor Senior Attorney

PROTECT•PREVENT•PRESERVE Legal Branch - Government Law Bureau 300 Capitol Mall, 17th Floor Sacramento, California 95814 Tel: (916) 492-3207 - Email: [email protected]

EXHIBIT 13

October 22, 2019

VIA EMAIL AND OVERNIGHT DELIVERY

Chao Lor California Department of Insurance 300 Capitol Mall, Suite 1700 Sacramento, CA 95814 Email: [email protected] Tel.: (916) 492-3207

RE: Public Records Act Requests – PRA-2019-00555 and PRA-2019-00697

Dear Ms. Lor,

On September 4, September 13, and September 16 the Department provided partial productions of records responsive to Consumer Watchdog’s requests for Commissioner Lara’s calendar of meetings (“Conferences”) and certain Communications, as defined in the above-captioned Public Records Act (“PRA”) requests. These requests were narrowed to target specific individuals and companies. Disclosure of such public records in full is essential to restoring the public trust in the Office of the Insurance Commissioner in the wake of news reports of influence peddling involving Commissioner Lara and insurance companies regulated by the Department.

In letters accompanying all three productions, the Department stated, without support, that certain responsive records were withheld because they were either privileged or otherwise exempt from disclosure. For example, regarding the calendar entries provided on September 13, on many days there are no entries of meetings whatsoever, suggesting those records have been heavily expurgated and do not reveal the full picture of Commissioner Lara’s Conferences and Communications relevant to the reports of influence peddling. We also note that only a single email and a single text from Commissioner Lara were produced.

In addition, Consumer Watchdog understands that instead of producing Commissioner Lara’s actual calendars as they appear in their native format(s), the Department created a new document and selected, and in some instances altered, the actual calendar entries it chose to produce. Under the PRA, the Department must provide the original records. Please provide copies of the original documents immediately.

October 22, 2019 Page 2 of 3

As we have previously noted, the Department’s concern that producing these records would chill the “deliberative process” have no place where the public interest at stake is whether the regulated companies or Commissioner Lara violated state or federal law. (See Times Mirror Co. (1991) 53 Cal.3d 1325, 1341.) The Times Mirror decision notes that focused requests like those at issue here outweigh any interest in keeping public records from the public view.

[W]here the public interest in certain specific information contained in one or more of the [elected official’s] calendars is . . . compelling, [and] the specific request more focused; then, the court might properly conclude that the public interest in nondisclosure does not clearly outweigh the public interest in disclosure, whatever the incidental impact on the deliberative process.

(Times Mirror Co., 53 Cal.3d at 1345–46). In other words, the Times Mirror court

cautioned that ‘[n]ot every disclosure which hampers the deliberative process implicates the deliberative process privilege. Only if the public interest in nondisclosure clearly outweighs the public interest in disclosure does the deliberative process privilege spring into existence. The burden is on the [elected official] to establish the conditions for creation of the privilege.’

(Labor & Workforce Dev. Agency v. Superior Court (2018) 19 Cal.App.5th 12, 28, review denied (Apr. 25, 2018) [emphasis added] [quoting California First Amendment Coal. v. Superior Court (1998) 67 Cal.App.4th 159, 172–73]; see also Caldecott v. Superior Court (2015) 243 Cal.App.4th 212, 226 [holding there was “not a sufficient showing the public interest in nondisclosure outweighs the interest in disclosure. . . . Rather . . . the public interest in disclosure is compelling and is not overcome by the limited, qualified public disclosure exemption.”].) For example, in one case the Court of Appeal “conclude[d] that the public interest served by revealing the names of the pharmaceutical companies and others from whom [government officials] sought to obtain [lethal injection drugs] clearly outweighs that favoring nondisclosure.” (American Civil Liberties Union of Northern California v. Superior Court (2011) 202 Cal.App.4th 55, 77–78.)

Moreover, the blanket withholding of documents without giving Consumer Watchdog enough information to determine whether the withholding is proper is inconsistent with the spirit of the PRA. The Department’s blanket statements of exemption and privilege give no information about how many documents are being withheld, or pursuant to which of the claimed privileges and exemptions they are being withheld. For example, is one document being held on the basis of attorney client privilege, or one thousand?

October 22, 2019 Page 3 of 3

Though the Department refused our request to produce a privilege log detailing the withheld records, the Department should nonetheless provide sufficient information to enable Consumer Watchdog to determine whether the claimed exemptions and privileges are justified.

We therefore request that you provide us with additional information about the type and amount of documents withheld pursuant to each claimed exemption or privilege. Otherwise we will have no choice but to assume that records are being wrongfully withheld and we will be forced to seek an order compelling their production.

Therefore, consistent with Cedars-Sinai Med. Ctr. v. Superior Court (1998) 18 Cal. 4th 1, 12-13, this letter demands that you preserve all records responsive to the above PRA requests, including electronically stored information (“ESI”) on all computers, tablets, flash drives, CD Rom discs, handheld devices, smartphones, and any other media, whether digital or non-digital. The ESI and other records to be preserved include, but are not limited to, all “writings” as defined by Evidence Code § 250: “handwriting, typewriting, printing, photostating, photographing, photocopying, transmitting by electronic mail or facsimile, and every other means of recording upon any tangible thing, any form of communication or representation, including letters, words, pictures, sounds, or symbols, or combinations thereof, and any record thereby created, regardless of the manner in which the record has been stored.”

This demand includes all digital messages, emails, text messages, videotapes, files, “tweets,” Facebook posts, and other online communications and voicemail messages.

Failure to preserve these records could result in sanctions, costs, attorney fees, and any other remedies that may be available under the law.

Respectfully submitted,

Jerry Flanagan Litigation Director (310) 392-2632

EXHIBIT 14

RICARDO LARA CALIFORNIA INSURANCE COMMISSIONER

October 31, 2019

VIA EMAIL ONLY

Jerry Flanagan Consumer Watchdog 6330 San Vicente Blvd., Suite 250 Los Angeles, CA 90048

RE: Public Records Act Requests - PRA-2019-00555 and PRA-2019-00697

Dear Mr. Flanagan:

This letter is in response to your letter dated October 22, 2019. Your letter requests the California Department of Insurance ("CDI") do the following: 1) provide you with a copy of Commissioner Lara's actual calendars as they appear in their native format(s); 2) provide you with additional information about the type and amount of documents withheld pursuant to each claimed exemption or privilege; and 3) preserve all records responsive to the above referenced Public Records Act ("PRA") requests.

Please be advised that the CDI will not provide you with another version of Commissioner Lara's calendars as requested. On September 13, 2019, the CDI provided you with all responsive calendars and a letter detailing what types of information were not disclosed and under what exemptions or privileges. Certain information was not produced, for instance, because it relates to the Commissioner's personal matters or personnel activities and these types of information are exempt from disclosure under the PRA.

The COi will not provide you with additional information about the type and amount of documents withheld pursuant to each claimed exemption or privilege because it is not required to do so. (Haynie v. Superior Court of Los Angeles (2001) 26 Cal.4th 1061.) As you were previously advised the CDI fulfilled its duties and responsibilities under the PRA when it provided a list of exemptions and/or privileges for information redacted or records withheld in its entirety in its September 3, September 13, and September 16 productions.

PROTECT•PREVENT•PRESERVE Legal Branch - Government Law Bureau 300 Capitol Mall, 17th Floor Sacramento, California 95814 Tel: (916) 492-3207 - Email: [email protected] Jerry Flanagan Page 2 October 31, 2019

Finally, the COi retains all business records pursuant to its records retention policy and will retain all the responsive records to these PRA requests in accordance with its retention policy.

Thank you in advance for your courtesy and consideration. z;;~ Chao Lor Senior Attorney

#1111918.1

EXHIBIT 15

EXHIBIT 16

California Secretary of State - CalAccess - Campaign Finance http://cal-access.sos.ca.gov/Campaign/Committees/Detail.aspx?...

Advanced Search Campaign Finance: LARA FOR INSURANCE COMMISSIONER 2022; RICARDO Candidates & Elected Officials

Propositions & Election Cycle: Ballot Measures 2019 through 2020

Committees, Parties, Historical Major Donors & Slate Mailers View Information: Daily/Late/ (Due to the amount of data, these pages may take some time to load.) Special Filings General Information Contributions Received Contributions Made Expenditures Made Late and $5000+ Contributions Received Late Contributions Made Late Independent Expenditures Electronic Filings

In addition to filing regularly required campaign disclosure statements, candidates, officeholders, ballot measure committees, political parties, PACs, and major donors may file late contribution reports and other special filings. These usually occur in the 90 days preceding Election Day. Contributions and independent expenditures of $1,000 or more are disclosed within 24 hours of the time they are made or received. You may search in this section by filer, by date, by candidate, and by proposition. At any other time, contributions of $5,000 or more are disclosed within 10 days.

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Late and $5000+ Contributions Received

NAME OF CONTRIBUTOR CITY STATE/ZIP

THERESA DEBARBRIE OCEAN CITY NJ / 08226

ID NUMBER EMPLOYER OCCUPATION

BARROW STREET NURSERY SCHOOL ADMINISTRATIVE COORDINATOR

AMOUNT TYPE TRANS. DATE FILED DATE TRANS #

$7,700.00 INITIAL 4/16/2019 4/30/2019 2380326-INC28

NAME OF CONTRIBUTOR CITY STATE/ZIP

STEPHEN H. ACUNTO MOUNT VERNON NY / 10552

ID NUMBER EMPLOYER OCCUPATION

CINN GROUP, INC. PRESIDENT

AMOUNT TYPE TRANS. DATE FILED DATE TRANS #

1 of 3 7/16/19, 1:05 PM California Secretary of State - CalAccess - Campaign Finance http://cal-access.sos.ca.gov/Campaign/Committees/Detail.aspx?...

$7,700.00 INITIAL 4/16/2019 4/30/2019 2380326-INC27

NAME OF CONTRIBUTOR CITY STATE/ZIP

CAROLE H. ACUNTO YONKERS NY / 10705

ID NUMBER EMPLOYER OCCUPATION

PLATIMUM EYE PRODUCTIONS, LLC & PRESIDENT & EXECUTIVE PRODUCER MEDIA MEASURE MEDIA, LLC

AMOUNT TYPE TRANS. DATE FILED DATE TRANS #

$7,700.00 INITIAL 4/16/2019 4/30/2019 2380326-INC26

NAME OF CONTRIBUTOR CITY STATE/ZIP

STEPHEN H. ACUNTO MOUNT VERNON NY / 10552

ID NUMBER EMPLOYER OCCUPATION

CINN GROUP, INC. PRESIDENT

AMOUNT TYPE TRANS. DATE FILED DATE TRANS #

$7,800.00 INITIAL 4/16/2019 4/30/2019 2380326-INC21

NAME OF CONTRIBUTOR CITY STATE/ZIP

CAROLE H. ACUNTO YONKERS NY / 10705

ID NUMBER EMPLOYER OCCUPATION

PLATIMUM EYE PRODUCTIONS, LLC & PRESIDENT & EXECUTIVE PRODUCER MEDIA MEASURE MEDIA, LLC

AMOUNT TYPE TRANS. DATE FILED DATE TRANS #

$7,800.00 INITIAL 4/16/2019 4/30/2019 2380326-INC20

NAME OF CONTRIBUTOR CITY STATE/ZIP

THERESA DEBARBRIE OCEAN CITY NJ / 08226

ID NUMBER EMPLOYER OCCUPATION

BARROW STREET NURSERY SCHOOL ADMINISTRATIVE COORDINATOR

AMOUNT TYPE TRANS. DATE FILED DATE TRANS #

$7,800.00 INITIAL 4/16/2019 4/30/2019 2380326-INC19

NAME OF CONTRIBUTOR CITY STATE/ZIP

DARLENE GRABER AUSTIN TX / 78750

ID NUMBER EMPLOYER OCCUPATION

NONE HOMEMAKER

AMOUNT TYPE TRANS. DATE FILED DATE TRANS #

$7,800.00 INITIAL 4/24/2019 4/25/2019 2377135-INC24

NAME OF CONTRIBUTOR CITY STATE/ZIP

JEFFREY THORN BROOLINE MA / 02446

ID NUMBER EMPLOYER OCCUPATION

2 of 3 7/16/19, 1:05 PM California Secretary of State - CalAccess - Campaign Finance http://cal-access.sos.ca.gov/Campaign/Committees/Detail.aspx?...

ADKINS KELSTON & ZAVEZ P.C. ATTORNEY

AMOUNT TYPE TRANS. DATE FILED DATE TRANS #

$15,500.00 INITIAL 4/11/2019 4/23/2019 2376384-INC22

3 of 3 7/16/19, 1:05 PM

EXHIBIT 17

2/7/2020 Release of Lara's Calendar and Public Records Suggest Lara Made First Contact In “Pay to Play” Insurance Scandal | Consumer Watchdog Subscribe to receive consumer alert emails SIGN UP! › ×

Release of Lara's Calendar and Public Records Suggest Lara Made First Contact In “Pay to Play” Insurance Scandal (/insurance/release-laras-calendar-and-public-records-suggest- lara-made-rst-contact-pay-play)

 Thu, 09/19/2019 - 09:27  Posted in: INSURANCE (/INSURANCE)

Raises Questions About Cleansing of Calendar and Role of Lena Gonzalez

UPDATE: 9/20 Consumer Watchdog sent this letter (https://www.consumerwatchdog.org/sites/default/les/2019-09/9-19- 19LetterReICLaraPlusRelease.pdf ) to the California Attorney General and District Attorneys for Sacramento, San Francisco and Los Angeles along with the information below.

Los Angeles, CA -- Calendar entries, documents, and newly uncovered photographs reveal that https://consumerwatchdog.org/insurance/release-laras-calendard-and-public-records-suggest-lara-made-first-contact-pay-play h f d d h f 1/9 2/7/2020 Release of Lara's Calendar and Public Records Suggest Lara Made First Contact In “Pay to Play” Insurance Scandal | Consumer Watchdog Insurance Commissioner Ricardo Lara, not his fundraiser, made rst contact with an agent of a Subscribe to receive consumer alert emails workers compensation insurance company offering political support in conjunction with seeking SIGN UP! › × approval for a change of control in the company.

New records, produced under the Public Records Act, appear incomplete and suggest Lara is not being fully forthcoming about his meetings. For example, the only email produced from Lara himself is one sent to Consumer Watchdog's president. Lara did not produce his texts, but a phone record from a Department ocial includes Lara's response approving a key meeting with principals in the scandal. Consumer Watchdog asked the Department to provide a privilege log of all the calendar entries and documents withheld to assess a potential Public Records Act challenge.

In addition, the records implicate a new political gure in the scandal, Lara’s handpicked-successor for his state senate seat Senator Lena Gonzalez.

Documents show that former New Mexico Superintendent of Insurance Eric Serna, who resigned in disgrace in the wake of a pay-to-play fundraising scandal, tried to broker Lara’s approval of the sale of Berkshire Hathaway-controlled California Insurance Company to his associate Steve Menzies, while offering fundraising and political assistance to Lara.

Serna is considered the Chuck Quackenbush of New Mexico. He resigned in 2006 as New Mexico Superintendent of Insurance under a cloud, including an attorney general investigation into a state contract Serna awarded to a Santa Fe bank that gave $129,000 to a charity that Serna founded. The chair of the state Public Regulation Commission cited “the continued entanglements with his private interests and his ocial duties” as the reason for his retirement.

Newly-uncovered photographs (https://consumerwatchdog.org/ricardo-lara-pictures) of a taxpayer- funded trip Lara took to New Mexico reveal Serna and Lara were together in late February in Santa Fe. The Santa Fe meetings were prior to March email communiques between Serna and Lara’s fundraising consultant, Dan Weitzman, that ignited the fundraising scandal and led to the ring of Weitzman and an apology from Lara. The photographs place Lara on the ground oor of the pay-to- play scandal with his arms around its kingpin, even though Lara claimed his fundraiser was to blame and he did not make the inappropriate overtures.

View a timeline of events: https://consumerwatchdog.org/sites/default/les/2019- 09/LaraTimelineSept.pdf (https://consumerwatchdog.org/sites/default/les/2019- 09/LaraTimelineSept.pdf)

Lara did not disclose the February contact with Serna in his Public Record Act release of his calendar of meetings Friday. Lara’s apology stated that “my campaign operation scheduled meetings and solicited campaign contributions that did not fall in line with commitments I made to refuse contributions from the insurance industry.” Yet, the photographs of Lara and Serna at an immigrant rights group event that Lara’s calendar notes he attended demonstrate Lara has not been fully forthcoming. https://consumerwatchdog.org/insurance/release-laras-calendar-and-public-records-suggest-lara-made-first-contact-pay-play 2/9 2/7/2020 Release of Lara's Calendar and Public Records Suggest Lara Made First Contact In “Pay to Play” Insurance Scandal | Consumer Watchdog Subscribe to receive consumer alert emails SIGN UP! › × Evidence shows Serna arranged and attended March meetings with Lara and his staff including both the buyer and seller of the workers compensation insurance company to discuss the company’s change of ownership approval and fundraising for “relationship building” for the Lara 2022 campaign. Serna is general counsel for Nelson Taplin Goldwater Consultants (NTG), an insurance consulting group whose Chairman is Barry Goldwater Jr., where his associates, related entities and son donated $23,500 in 2018 to the Lara campaign, donations that Lara has not returned.

Department correspondence involving Serna from early March paint a troubling picture of the mixing of ocial decisions and fundraising. However, the newly released calendar and Public Record Act responses show that taxpayers paid for Lara’s travel to and lodging in Santa Fe, where Serna is based, from February 25th – February 27th, just days before the troubling March fundraising emails. Lara’s calendars list only two events for which taxpayers picked up Lara’s Santa-Fe bills: a celebration at an immigration rights group, Somos Un Pueblo Unido, and an insurance panel the next morning.

Photographs of the immigrant rights group event, uncovered from an event photographer’s online gallery, show Lara spent that evening arm and arm with Serna, who introduced him from the podium and gave him an award. See the photographs here: https://consumerwatchdog.org/ricardo-lara- pictures (https://consumerwatchdog.org/ricardo-lara-pictures) (A separate photo gallery from the same photographer show Serna as central gure in a July celebration with Steve Menzies.)

Serna appears to be connective tissue in the Lara scandal. According to the recently released calendars, Serna and Lara had dinner in New York on April 10th, six days before the questionable donations owed to "Lara 2022" from associates and relatives aliated with insurance companies, mostly related to Menzies. Weitzman was also in New York and reimbursed by "Lara 2022" at the time. One mysterious donor not related to Menzies, Texas homemaker Darlene Graber, who gave $7800 to Lara, lives with Larry Graber, the head of an insurance company that sells "short term" health insurance policies banned in California. Lara's calendars state Serna met with Lara about "short term" health policies on January 30th and the April 10th dinner with Lara was with Serna and health insurers.

The fact that Lara ew to Santa Fe and met with Serna, just days before the unseemly March emails mixing Department decisions and fundraising began, suggest Lara, not Weitzman, was approached directly with a “pay to play” proposition. It also shows the release of Lara’s calendars, which were heavily expurgated, may not reveal the full picture of his actual dealings relevant to the fundraising scheme.

One day after Lara’s return from Santa Fe on March 1st, Lara’s fundraiser Dan Weitzman, Lara and his Department staff exchanged emails discussing meetings with the Menzies team about both fundraising and about California Insurance Company’s change of ownership. The pending change will have to be approved by September 30th according to Department statements. https://consumerwatchdog.org/insurance/release-laras-calendar-and-public-records-suggest-lara-made-first-contact-pay-play 3/9 2/7/2020will have to beRelease approved of Lara's Calendar by September and Public Records 30th Suggest according Lara Made First to DepartmentContact In “Pay to Play” statements. Insurance Scandal | Consumer Watchdog Subscribe to receive consumer alert emails SIGN UP! › × Lara later attended a March 12th fundraising meeting described as the Berkshire Hathaway lunch meeting “to benet Ricardo Lara for Insurance Commissioner 2022” at Camden, Spit & Larder in Sacramento. Meeting attendees: Lara, Steve Menzies CEO Applied Underwriters, Jeff Silver Applied Underwriters counsel, Jamie Sahara Chairman of Cayman Islands-based United Insurance Company, Camille Alcala California Democratic Party Deputy Director of Finance), Dan Weitzman, Eric Serna.

View the meeting agenda: https://www.consumerwatchdog.org/sites/default/les/2019- 09/PRA2019-00555CDIMeetings30pdf.pdf (https://www.consumerwatchdog.org/sites/default/les/2019-09/PRA2019- 00555CDIMeetings30pdf.pdf)

On the same day, March 12th, information in a follow-up internal California of Department of Insurance (CDI) email thread describes “the highlights of what was discussed” in a meeting with staff members and is heavily redacted. Jeff Silver, a lawyer for the Berkshire-Hathaway subsidiaries, sent a follow-up email to Department employees saying “thank you for taking the time to visit with Eric, Steve Menzies and me concerning the soon to be led Form A for California Insurance Company. We look forward to working with you and your staff to meet the September 30, 3019 deadline.” [Form A is the paperwork seeking Lara’s approval of the acquisition of Applied Underwriters by Steve Menzies and United Insurance.]

Lena Gonzalez Received $25K From Menzies Associates, Pays Weitzman Ten days following the lunch meeting, on March 22nd, board members and a relative of a board member of Menzies-controlled Constitution Insurance Company sent $25,000 in campaign contributions to Lara ally and hand-picked state Senate successor Lena Gonzalez. According to campaign donation records compiled by the National Institute on Money in State Politics, none had previously donated in California political campaigns. All are on the board of directors, or related to a board member, of Menzies' Constitution Insurance Company, whose board overlaps with Applied Underwriters and California Insurance Company. Another $46,500 in campaign contributions were made to Lara by individuals connected to Menzies through Constitution Insurance Company, donations at the center of the fundraising scandal embroiling Lara. Lara returned those contributions. The $25,000 to Gonzalez came from:

Contributor Xiaoyun A. Hu, of Burlingame, California, is identied as a manager of the Constitution Group by the SOS. He is also a member of the Board of Directors of Constitution Insurance Company. Hu contributed $8,500 to Gonzalez on March 22, 2019. Contributor Pei H. Hu, apparently a relative of Xiaoyun A. Hu, is identied as a manager of the King Chuan Restaurant in SOS records. She contributed $8,000 to Gonzalez on March 22, 2019. Contributor Katy Van Horn, of Castro Valley, CA, is identied by the SOS as a business owner. She is also a member of the Board of Directors of Constitution Insurance Company. Van Horn https://consumerwatchdog.org/insurance/release-laras-calendarb d $ l-and-public-records-suggest-lara-made-first-contact-pay-play h 4/9 2/7/2020 Release of Lara's Calendar and Public Records Suggest Lara Made First Contact In “Pay to Play” Insurance Scandal | Consumer Watchdog contributed $8,500 to Gonzalez on March 22, 2019. Subscribe to receive consumer alert emails SIGN UP! › × A day after the contributions were made to Lena Gonzalez, on March 23rd, Lara’s Facebook page shows he participated in GOTV events for Gonzalez in Long Beach. Three days after the contributions, on March 25th, Lena Gonzalez for Senate 2019 paid Lara fundraiser Dan Weitzman $12,000 for campaign consulting. On June 10th, Lena Gonzalez for Senate 2019 paid Dan Weitzman another $12,000 for campaign consulting. In total, Gonzalez has paid Weitzman $24,000, almost exactly the amount she received in campaign contributions from people connected to Menzies, including an extra $210 paid for expenses on April 20th.

The contributions raise serious questions: Did Lara receive any of the money paid by Gonzalez to Weitzman? Did Steve Menzies, new owner of California Insurance Company in the pending sale, launder contributions through Gonzalez and board members of the interlocking companies in order to hide their true source and avoid campaign spending limits? Were the contributions intended to inuence Lara’s approval of the pending sale, actions that would constitute a bribe under state law?

Gonzalez’s name surfaces again in an April 24th text message to Lara from a Department employee's phone (Lara did not produce his texts), seeking to schedule a lunch in May with "Lena Gonzales and Steve Menzies." Lara replies "OK." A subsequent May 1st email from Jamie Sahara CEO of Cayman Islands-based United Insurance, the buyer in the California Insurance Company deal, is the most vivid example of policy discussions alongside fundraising. Sahara’s company is in the middle of the Berkshire/Applied Underwriters/Menzies sale – as it entered into a stock purchase agreement with Berkshire to buy Applied & transfer control to Menzies.

In the below email from a chain between Jamie Sahara, David Green Special Assistant at the Department of Insurance, and Dan Weitzman, Sahara discusses lunch (presumably the same lunch Lara received the text about) between Weitzman Gonzalez Menzies Sahara and Lara : https://consumerwatchdog.org/insurance/release-laras-calendar-and-public-records-suggest-lara-made-first-contact-pay-play 5/9 2/7/2020 Release of Lara's Calendar and Public Records Suggest Lara Made First Contact In “Pay to Play” Insurance Scandal | Consumer Watchdog Lara received the text about) between Weitzman, Gonzalez, Menzies, Sahara and Lara : Subscribe to receive consumer alert emails SIGN UP! › × “We would like to schedule two meetings with the Commissioner:

1. Formal policy discussion with the Commissioner to discuss the California Insurance Company.

2. Political meeting with the Commissioner, Lena Gonzalez, and Dan Weitzman”

View the email: https://www.consumerwatchdog.org/sites/default/les/2019-09/PRA2019- 00555CDIMeetings47.pdf (https://www.consumerwatchdog.org/sites/default/les/2019- 09/PRA2019-00555CDIMeetings47.pdf)

While that one email suggests two meetings, only one appears to be scheduled. Records reect a lunch meeting on May 6, 2019, from 12:00 – 2:00pm at NoMad in Los Angeles, with Steve Menzies & Jamie Sahara; Dan Weitzman may also have been in attendance; multiple records appear to notify other people who may or may not have attended: Catalina Hayes-Bautista (Lara’s CDI chief-of-staff), Angela Lizarraga (formerly a member of Lara’s Senate staff), Roberta Potter (Lara’s CDI appointment scheduler).

Why Lara’s fundraiser, Weitzman, was involved in multiple meetings about ocial Department business is another troubling issue for Lara. It suggests that ocial Department decisions are being discussed simultaneously to fundraising and that one is being leveraged for the other.

In addition, at least four decisions were made by Administrative Law Judges against the workers compensation insurer Menzies sought to buy, then overturned in the company’s favor by Lara, in the midst of these meetings and email communications with the Berkshire-Hathaway team, and as contributions from them were owing covertly through Menzies’ associates and their relatives.

“The new documents suggest state laws involving money laundering, bribery and misuse of public monies may have been violated, raising the stakes for a state prosecutor or the Attorney General to investigate this troubling circumstantial evidence and nd out what was said and promised in these meetings,” said Jamie Court, president of Consumer Watchdog.

View the calendar records produced under the Public Records Act: https://consumerwatchdog.org/sites/default/les/2019-09/PRALaraCalendarJan-Aug_0.pdf (https://consumerwatchdog.org/sites/default/les/2019-09/PRALaraCalendarJan-Aug_0.pdf)

View the communications mixing fundraising with Department business: https://consumerwatchdog.org/sites/default/les/2019- 09/PRAAppliedCommunications.pdf (https://consumerwatchdog.org/sites/default/les/2019- 09/PRAAppliedCommunications.pdf)

View the slideshow referred to in the press brieng below: https://www consumerwatchdog org/sites/default/les/2019-09/Lara%20Calendar%20Slides pdf https://consumerwatchdog.org/insurance/release-laras-calendar-and-public-records-suggest-lara-made-first-contact-pay-play 6/9 2/7/2020 Release of Lara's Calendar and Public Records Suggest Lara Made First Contact In “Pay to Play” Insurance Scandal | Consumer Watchdog https://www.consumerwatchdog.org/sites/default/les/2019 09/Lara%20Calendar%20Slides.pdf (https://www.consumerwatchdog.org/sites/default/les/2019-09/Lara%20Calendar%20Slides.pdf)Subscribe to receive consumer alert emails SIGN UP! › ×

Press Conference on Insurance Commis…

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EXHIBIT 18

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