RESUME

J. ALAN FREDERICK

Martindale-Hubbell Peer Review Rated AV Preeminent

MARRONE, ROBINSON, FREDERICK & FOSTER

A Professional Corporation

111 North First Street, Suite 209

Burbank, CA 91502-1851

Education:

University of California at Santa Barbara (B.A., 1971, highest honors); University of California at Los Angeles (J.D., 1974); Moot Court Honors Program; Admitted to Bar, 1974, California; Admitted to U.S. District Court, Central, Northern and Southern Districts of California.

Member:

State Bar of California, Litigation Section; Arbitrator, Los Angeles Superior Court, 1979 to 1985; Association of Southern California Defense Counsel; Settlement Officer, JASOP Program, Los Angeles Superior Court; Former Member, Professional Liability Underwriting Society; Member, American Trial Lawyers Association.

Publications:

California Continuing Education of the Bar, CaliforniaLiability Insurance Practice, Interpleader Chapter

California Continuing Education of the Bar, CivilProcedure Before Trial, Interpleader Chapter

Bancroft and Whitney, Consultant, California CivilLitigation, Torts

Bancroft and Whitney, Consultant, California CivilLitigation, Civil Procedure

Jury Trial Experience:

Mr. Frederick is an experienced trial and appellate attorney specializing in insurance coverage matters and bad faith and declaratory relief litigation, professional errors and omissionslitigation, medical and health care provider malpractice litigation, indemnity and construction litigation, products liability litigation, general and premises liability litigation, general liability litigation, intellectual property litigation, toxic tort litigation, and appellate litigation.

He has also drafted insurance policy language on behalf insurer clients, and participated in drafting proposed legislation on insurance matters. He has appeared as an expert witness in insurance coverage matters.

Significant Matters:

Mr. Frederick has been the principal Southern California insurance and general liability attorney for Sony Pictures Entertainment, Inc., and its subsidiary companies; a Southern California litigation attorney for NACCO Materials Handling Group (Hyster and Yale Forklifts and related equipment); and was formerly the Chief Litigation Counsel for the Alliance of Insurance Agents & Brokers (at the time the largest association of independent California insurance agents and brokers).

In 40 years of civil litigation practice, Mr. Frederick has taken dozens of cases to trial and has only two jury trials in which the award was more than the amount offered to settle (one by $2,000, and the other reversed on appeal with JNOV for the defendant/appellant). All other defense matters resulted in judgment for the defendant or an award of less than the settlement offer.

In cases defended, the highest demand made to a jury by opposing counsel (Browne Greene) was $8 million and the case resulted in a defense verdict in favor of Mr. Frederick’s client in 1.5 hours.

In plaintiff cases, the highest award in favor of Mr. Frederick’s client was $1.77 million (affirmed on appeal). During trial, another plaintiff insurance bad faith case handled by Mr. Frederick settled for $4 million. In his most recent coverage related trial, Mr. Frederick prevailed on a declaratory relief action by establishing that the insured failed to report a claim in advance of the inception of the claims made policy.

Appellate Cases (Published):

1. Wechsler v. Home Savings & Loan Assn., 57 Cal. App. 3d 563, 129 Cal. Rptr. 380 (1976)

2. Alameda Tank Co. v. Starkist Foods, Inc., 103 Cal App. 3d 428, 162 Cal Rptr. 924 (1980)

3. Wynn v. Monterey Club, 111 Cal. App. 3d 789, 168 Cal. Rptr. 878 (1980)

4. Aetna Casualty & Surety Co. v. Superior Court, 114 Cal. App. 3d 49, 170 Cal. Rptr. 527 (1980)

5. C.I. Engineers & Constructors, Inc. v. Johnson & Turner Painting Co., 140 Cal. App. 3d 1011, 189 Cal. Rptr. 824 (1983)

6. American Empire Surplus Lines Ins. Co. v. G.E. Leach Construction, 223 Cal. App. 3d 226, 272 Cal. Rptr. 704 (1990)

7. Garcia v. Hyster Company, 28 Cal. App. 4th 724, 34 Cal. Rptr. 2d 283 (1994)

8. Amos v. Alpha Property Management,73 Cal. App. 4th 895, 87 Cal. Rptr.2d 34 (1999)

9. Royal Surplus Lines Ins. Co., Inc. v. Ranger Ins. Co., 100 Cal. App. 4th 193, 122 Cal. Rptr. 2d 459 (2002)

Mr. Frederick has participated in many other non-published appeals on a wide range of issues, in all areas of his practice including insurance overage matters. He has been successful in a number of Petitions for Writ of Mandate in overturning rulings of trial courts. He also participated in appeals as amicus curiae.

Representative Clients:

Acceptance Insurance Company; Acceptance Risk Managers, Inc.; Admiral Insurance Company; American Agents Alliance; Berkeley Risk; Catlin Insurance Company; City of Burbank; Clarendon America Reinsurance; Collier-Keyworth Company; Columbia Pictures Industries, Inc.; Columbia Records; Dyna-Span Corporation; Emhart Industries, Inc.; Epic Records; General Star Insurance Company; Hyster Company; Investor’s Insurance Group; KB Insurance Co. Ltd, US Branch; Los Angeles Turf Club; Magna Entertainment Corporation; Maxon Industries; MCA Inc.; NACCO Materials Handling Group, Inc.; National Presto Industries, Inc.; Norton Company; Oaktree Racing Association; Omark Industries, Inc.; Paramount Pictures Corporation; Parsons Corporation; Progressive Casualty Insurance Company; Public Service Mutual Insurance Company; Risk Enterprise Management, Ltd./Home Insurance Company; Royal & SunAlliance Insurance Company; Santa Anita Racetrack; Simcoe & Erie General Insurance Company; Sony Music Entertainment Inc.; Sony Pictures Entertainment, Inc; Sony Studios, Inc.; Textron, Inc.; Tokio Marine & Fire Insurance Company; The Travelers Company; Tri-Star Pictures; Underground Technology, Inc.; United Pacific Insurance Company; Unisen, Inc.; Universal City Studios, Inc.; U.S. Liability Insurance Company; and Wickes Companies, Inc.

Page 1