Contract analysis

I. Executive Summary Between April and May 2023, a total of eighteen (18) depositions were taken across the consolidated class action (Fuentes v. Aurelius Media Americas Inc., LASC Case No. 22STCV38214) and the related individual action (Aldrich v. Aurelius Media Americas Inc., LASC Case No. 22STCV41087). Of these depositions, eleven (11) were noticed and taken by Plaintiffs or by Aldrich's counsel, and seven (7) wer

II. Named Plaintiff Depositions A. Marisol Fuentes — May 2, 2023 (6 hrs. 22 min.) Background. Marisol Fuentes is a former Production Coordinator in AMA's Unscripted Programming Division. She was employed by AMA from March 14, 2019 through August 5, 2022 — a period of approximately three years and five months. Throughout her employment, Ms. Fuentes worked at AMA's Studio City facility, designated internally as Facilit

III. AMA Witness Depositions D. Lorraine Okafor (PMK — Timekeeping and Meal/Rest Break Policies) — May 4, 2023 (7 hrs. 0 min.) Background. Lorraine Okafor is the Senior Vice President of Human Resources at AMA. She has held this position since June 2019, having joined AMA from a prior human resources leadership role at another entertainment company. Ms. Okafor was designated as AMA's Person Most Knowledgeable ("PMK")

I. Gavin Aldrich — May 22, 2023 (7 hrs. 0 min.) Background. Gavin Aldrich is the former Senior Vice President of Original Content and Executive Producer at AMA. He was employed by AMA from September 5, 2017 through October 14, 2022 — a period of slightly more than five years. At the time of his termination, his base salary was $485,000 per year, and his most recent annual bonus (for fiscal year 2021) was $225,000. He