Quan

I.

FACTUAL AND PROCEDURAL

BACKGROUND

The relationships among the various entities involved in this dispute are unclear, as they are not succinctly described in the record or in the parties’ briefing. As we understand it, respondent Acrisure of California, LLC is an insurance company that owns various partner firms doing business under different names. One of these firms is respondent Vantreo Insurance Brokerage Firm, “a full-service brokerage firm offering a broad range of property/casualty, employee benefits, life insurance, long term care, personal insurance coverages, and risk management solutions.” Wallace, who is White, has been with Vantreo since 2008 and is the president and chief executive officer of the company. She is also an employee and officer of Acrisure, where she has worked since 2018. Holzman, who is also White, is the principal and chief operating officer (COO) of another Acrisure partner, Cumbre Insurance, where he started in 1991; and he has

2 been employed by Acrisure since 2015. He is based in Cumbre’s Ontario, California office. Quan is of Chinese descent, and he has worked in the insurance industry since 1977. He has an insurance broker’s license and…