Allstate (ALL)

RECITALS

A.            Certain claims, demands and differences have existed heretofore between the Plaintiff Class and Defendant, including Plaintiff Class’ contention that Defendant failed to pay members of the Plaintiff Class (“Class Members”) overtime pay and/or to provide them paid rest breaks and/or unpaid meal periods (collectively, “Breaks”) as required by law and Defendant’s contention that the Class Members are exempt from such requirements.

B.            The Plaintiff Class and Defendant are parties to a civil action, bearing case number BC 240 813 pending in the Superior Court of the State of California for the County of Los Angeles (“the “Court”), entitled William Sekly vs. Allstate Insurance Company, and filed on or about November 27, 2000 (“the Lawsuit”).

C.            The operative complaint in the Lawsuit shall be the amended complaint (the “Class Complaint”) referred to in paragraph 5 below, which alleges, among other things, that Defendant improperly classified the Class Members as exempt employees, misrepresented that such Class Members were exempt employees, and failed to pay overtime compensation and/or to provide Breaks to such Class Members. Defendant denied said allegations in their entirety and alleged that the Class Members were properly classified as exempt employees and that any and all compensation and/or Breaks due to such Class Members was paid and/or provided according to law.

D.            The matter has been litigated before the Hon. Anthony Mohr, Judge of the Court.

E.             On August 23, 2002, the Court, over Defendant’s objection, certified this matter as a class action for the determination of the issue of liability, and on January 19, 2005, the Court, again over Defendant’s objection, further certified this matter as a class action for the determination of damages.

F.             The Court has approved the following law firms as “Class Counsel” for the Plaintiff Class: