Contract analysis

I. Overview Celine Arroyo, Director of Production Operations for Aurelius Media Americas Inc. ("AMA"), has been designated as AMA's Person Most Knowledgeable ("PMK") on the following deposition topics noticed by Plaintiffs in the above-referenced consolidated wage-and-hour class action. Plaintiffs are represented by Castellano Byrne & Salas LLP ("CB&S"), with Marco Castellano and Diane Salas serving as lead class cou

II. Background on Celine Arroyo Ms. Arroyo currently holds the title of Director of Production Operations for AMA and reports directly to Jonathan Mercer, President of AMA. In this capacity, Ms. Arroyo is responsible for overseeing day-to-day production operations across all seven of AMA's California production facilities. Her responsibilities encompass the supervision and coordination of production scheduling, crew

III. AMA California Production Facilities and Show Units — Key Facts for Preparation Ms. Arroyo should be thoroughly conversant with the operational profile of each of the seven California production facilities and the fourteen show units that operated during the class period. This section summarizes the key facts that she should be prepared to discuss. A. Facilities AMA operates seven production facilities in Califo

IV. Key Documents for Review Ms. Arroyo should review the following documents in preparation for her deposition. These documents should be assembled in a preparation binder for use during the preparation session. Nadia Petrov will be responsible for assembling this binder.

1. AMA Employee Handbook (March 2021 revision) — particularly Section 4.3 (Meal Periods), Section 4.4 (Rest Periods), and Section 4.7 (Timekeeping). Ms. Arroyo should be familiar with the substance of these policies, though she should not be expected to recite them verbatim.

2. AMA Meal and Rest Break Policy (standalone document, effective January 1, 2019) — this is the standalone policy document that sets forth AMA's meal and rest break requirements in greater detail than the Employee Handbook. Ms. Arroyo should be familiar with the key provisions of this policy, including the applicable thresholds for meal period eligibility and the procedures for reporting missed meals.

3. Representative daily call sheets for at least five to six show units spanning different production types (studio-based, field-based, live events, post-production, and digital content). Ms. Arroyo should review these call sheets to refresh her recollection regarding how meal breaks are typically designated on call sheets and how call times are set for different types of production days.

4. Representative wrap reports for extended production days (twelve-plus-hour shifts) — particularly from "Summit Challenge" and live event productions. Wrap reports document the actual timing of events during the production day, including wrap time, and can be compared against call sheets to assess whether the planned schedule was followed.

5. Production schedules for representative show units during the class period — these are the broader scheduling documents that outline the planned production calendar for each show unit, including shooting dates, locations, and anticipated crew requirements.

6. AMA organizational charts showing the supervisory chain from Arroyo to UPMs and Line Producers and from UPMs and Line Producers to crew members. These charts are relevant to Topic 6 (staffing levels and supervisor-to-employee ratios) and will help Ms. Arroyo testify accurately about reporting relationships and supervisory structures.

7. Staffing rosters for each facility with supervisor-to-employee ratios for each show unit and facility type. Ms. Arroyo should be prepared to provide at least approximate ratios during her testimony.

8. Any written production protocols or guidelines provided to UPMs and Line Producers regarding the scheduling of meal and rest breaks during production days. The existence and content of these guidelines are significant — if AMA provided written guidance to UPMs regarding break scheduling, this supports the argument that AMA had policies and procedures in place to ensure compliance. If no written guidelines exist, M

9. TimeTrack Pro system overview — Ms. Arroyo need not be the technical expert on AMA's timekeeping system, but she should have a basic understanding of how the TimeTrack Pro system interfaces with production scheduling and call times. She should understand, at a high level, how employees clock in and out, how the system records work hours, and how the system interacts with the daily call sheet and production schedul

10. Named plaintiffs' deposition transcripts — Marisol Fuentes's deposition is scheduled for May 2, 2023. If the Fuentes transcript is available before Ms. Arroyo's deposition, she should review it to understand the specific factual allegations and testimony of the lead named plaintiff. Yesenia Padilla's deposition is scheduled for May 9, 2023, and Derek Halloran's deposition is scheduled for May 16, 2023. These tran

11. Lorraine Okafor's PMK deposition transcript — Ms. Okafor is designated as AMA's PMK on Topics 1, 2, 3, 5, and 8 (timekeeping and meal/rest break policies). Her deposition is scheduled for May 4, 2023. It is essential that we coordinate the preparation of Ms. Arroyo and Ms. Okafor to ensure consistency between their testimony, particularly on overlapping topics such as AMA's meal period policy and the functionalit

V. Key Messages Ms. Arroyo should communicate the following themes throughout her testimony. These themes should not be delivered as rehearsed talking points but should emerge naturally from her answers as the underlying factual narrative of her testimony. Each theme is discussed below, together with the supporting facts and specific examples that Ms. Arroyo should be prepared to discuss. Message 1: Production Schedu

VI. Sensitive Areas — Preparation Notes The following areas are identified as particularly sensitive and require careful preparation. These are the areas where Plaintiffs' counsel is most likely to press for admissions that could be harmful to AMA's defense, and where Ms. Arroyo's testimony must be both truthful and strategically disciplined. A. Extended Production Days and Second Meal Periods (Topic 9) This is a sig

VII. Anticipated Lines of Questioning by Plaintiffs' Counsel The following table identifies anticipated lines of questioning from Plaintiffs' counsel, together with suggested approaches for Ms. Arroyo's responses. These suggested approaches are guidelines, not scripts — Ms. Arroyo should answer each question in her own words and based on her personal knowledge, while keeping these strategic considerations in mind.

VIII. Coordination with Other PMK Depositions Coordination between Ms. Arroyo's testimony and the testimony of AMA's other PMK witnesses and key personnel is essential to ensuring consistency across AMA's deposition record. Lorraine Okafor (PMK: Timekeeping and Meal/Rest Break Policies — Topics 1, 2, 3, 5, and 8). Ms. Okafor's deposition is scheduled for May 4, 2023. Ms. Okafor will cover policy-level and system-leve

IX. Documents to Bring / Have Available at Deposition The following documents should be assembled and available at the deposition for reference by counsel and, where appropriate, for use as potential exhibits:

1. Representative call sheets for at least three to four show units, covering studio-based, field-based, live event, and post-production productions. These call sheets should be marked for identification as potential exhibits and should be reviewed by Ms. Arroyo during the preparation session so that she is familiar with their content and format.

2. AMA production protocols or guidelines for UPMs regarding break scheduling, if written guidelines exist. The existence of these written guidelines is an important element of AMA's defense — they demonstrate that AMA communicated break scheduling expectations to its supervisory personnel. If written guidelines do not exist, this is a point of vulnerability that should be addressed during the preparation session.

3. Organizational chart showing Ms. Arroyo's reporting relationships and the supervisory chain from Ms. Arroyo to UPMs and Line Producers and from UPMs and Line Producers to crew members.

4. AMA Employee Handbook (March 2021 revision) — the meal and rest break sections (Sections 4.3 and 4.4) and the timekeeping section (Section 4.7).

5. AMA Meal and Rest Break Policy (standalone document, effective January 1, 2019). All documents brought to the deposition should be reviewed by counsel for privilege before the deposition. Any privileged documents should not be included in the deposition binder.

X. Practice Session We recommend a three-hour preparation session with Ms. Arroyo to prepare her for the deposition. The proposed date for the preparation session is April 25, 2023, subject to confirmation with AMA and coordination around Ms. Okafor's preparation session, which is proposed for April 24, 2023. The preparation session should be structured as follows: First 45 minutes (Renata Vasquez attending): This po

XI. General Instructions for the Witness The following instructions should be provided to Ms. Arroyo during the preparation session and reinforced immediately before the deposition. These are standard deposition instructions for a PMK witness in a class action employment case, tailored to the specific risks and sensitivities of this deposition.

1. Listen carefully to each question before answering. Do not anticipate the question or begin formulating your answer before the questioner has finished speaking. Allow a brief pause after each question before responding.

2. Answer only the question asked. Do not provide narratives, explanations, or additional context unless necessary to avoid a misleading answer. A concise, direct answer is almost always preferable to a lengthy explanation. If Plaintiffs' counsel wants more detail, they will ask a follow-up question.

3. If you do not understand a question, ask for clarification. Do not guess at the meaning of a question. Say "Could you rephrase the question?" or "I'm not sure I understand what you're asking." It is Plaintiffs' counsel's obligation to ask clear questions; it is not your obligation to interpret ambiguous or confusing questions.

4. If you do not know the answer, say "I don't know." Do not guess or speculate. As a PMK witness, you are expected to have prepared to testify on the designated topics, but you are not expected to know every fact about AMA's operations. If the answer requires reference to documents or data that you do not have in front of you, say so and identify the appropriate source — for example, "Karen Fong would have that data

5. Do not characterize company practices in absolute terms. Avoid statements such as "We always provided breaks" or "No one ever worked off the clock." Such absolute statements are impossible to verify for a putative class of approximately 1,850 employees over a class period spanning more than four years. Any absolute statement will inevitably be contradicted by individual testimony or documentary evidence, and the c

6. If opposing counsel shows you a document, read it carefully before answering questions about it. Take as much time as you need to review the document. Do not answer questions about a document based on a quick glance. If the document is lengthy, ask which specific portion counsel is asking about.

7. If you need a break, say so. You are entitled to breaks during the deposition. If you are feeling fatigued, if you need to use the restroom, or if you need to consult with counsel about a privilege issue, request a break.

8. Do not discuss the substance of the deposition with anyone other than AMA's counsel during breaks. This includes other AMA employees, family members, and any other person. Conversations with AMA's counsel during breaks are protected by the attorney-client privilege, but conversations with anyone else are not. This memorandum is protected by the attorney-client privilege and the work product doctrine. It is prepare