Contract analysis

I. PURPOSE This Litigation Hold Notice is issued on behalf of Aurelius Media Americas Inc. ("AMA" or the "Company") to inform you of your obligation to immediately preserve all documents and electronically stored information ("ESI") that may be relevant to pending and anticipated litigation involving the Company. You must read this notice carefully, in its entirety, and comply with all instructions set forth herein.

II. MATTERS SUBJECT TO THIS HOLD This Litigation Hold Notice relates to the following pending and anticipated legal matters: A. *Fuentes v. Aurelius Media Americas Inc.* This is a putative class action and representative action filed on November 1, 2022, in the Superior Court of the State of California, County of Los Angeles, bearing Case No. 22STCV38214. The complaint alleges, among other things, violations of the C

III. SCOPE OF PRESERVATION You must preserve all documents and ESI that relate in any way to the following categories. This list is intended to be illustrative and not exhaustive. If you are uncertain whether a particular document or category of information falls within the scope of this hold, you should err on the side of preservation and contact Gregory Tanaka immediately for guidance.

1. Timekeeping Policies, Practices, and Systems. All documents and ESI relating to AMA's timekeeping policies, practices, and systems, including but not limited to the NovaPay Solutions "TimeTrack Pro" electronic timekeeping system, which has been in use at AMA since January 1, 2019. This includes all system configuration records, user manuals, implementation documentation, audit logs, system settings, administrator

2. Meal Period and Rest Break Policies and Practices. All documents and ESI relating to AMA's meal period and rest break policies, practices, schedules, and any waivers thereof, including but not limited to: (a) the automatic deduction feature currently in use in the TimeTrack Pro system, which automatically deducts thirty (30) minutes of unpaid time for shifts of six (6) hours or more; (b) the "Missed Meal Attestati

3. Payroll Records and Compensation Data. All payroll records, wage statements, pay stubs, and compensation data for non-exempt hourly employees based in California. This encompasses records for approximately 2,400 California-based employees, including approximately 1,850 putative class members whose employment falls within the class period beginning November 1, 2018. This category includes all records of regular and

4. Production Schedules and Operational Records. All production schedules, call sheets, wrap reports, and daily production logs for all California-based show units, including all fourteen (14) distinct production units operating across AMA's seven (7) California facilities. This includes any records reflecting the actual start and end times of production days, crew schedules, turnaround times, and any documentation o

5. Employee Handbooks, Policy Manuals, and Training Materials. All employee handbooks, policy manuals, and HR training materials related to wage-and-hour compliance, including but not limited to: (a) the most recent AMA Employee Handbook, revised March 2021; (b) the standalone Meal and Rest Break Policy, which became effective January 1, 2019; (c) any prior versions of these documents; (d) any training materials, pre

6. Communications Regarding Wage-and-Hour Matters. All communications — whether by email, text message, instant message, Meridian Solutions, Northgate Data Systems, or any other messaging platform — regarding meal breaks, rest breaks, overtime, scheduling, employee classification, or any other topic relating to the wage-and-hour practices at issue in the matters described in Section II above. This includes both inter

7. Personnel Files and Records for Named Plaintiffs. All personnel files, performance evaluations, disciplinary records, and employment-related documents for the following named plaintiffs and anticipated parties: (a) Marisol Fuentes — Production Coordinator, Unscripted Programming Division; employed March 14, 2019 through August 5, 2022. (b) Derek Halloran — Post-Production Assistant, Digital Content Division; emplo

8. All Communications To, From, or Concerning Gavin Aldrich. Without limiting the generality of any other category described in this Section III, all communications to, from, or concerning Gavin Aldrich must be preserved, including but not limited to: (a) Communications relating to Mr. Aldrich's job performance, performance reviews, supervisory assessments, or any evaluations of his work product or conduct during his

9. Internal Investigations, Audits, and Compliance Reviews. All documents and ESI relating to any internal investigations, audits, or reviews of wage-and-hour compliance at AMA, whether conducted by AMA personnel, outside counsel, or third-party consultants or auditors. This category also includes any DLP audits, IT security reviews, or forensic examinations conducted in connection with any of the matters described i

10. Employee Complaints and Grievances. All complaints, grievances, reports, or other communications filed, submitted, or raised by non-exempt employees regarding wages, hours worked, meal breaks, rest breaks, or working conditions, whether such complaints were made formally (e.g., through an HR complaint process) or informally (e.g., through email, conversation, or other channels). This includes any records of inves

IV. TYPES OF MATERIALS TO PRESERVE The preservation obligation described in this notice applies to all forms of information, regardless of format or medium. You must preserve all potentially relevant materials in whatever form they exist, including but not limited to the following: • Emails and email attachments, including all emails sent, received, drafted, or stored in your AMA email account (Exchange/Ashbury Softw

V. CUSTODIANS The following individuals have been identified as key custodians of documents and ESI that are likely to fall within the scope of this Litigation Hold. These individuals must take particular care to identify, locate, and preserve all materials within their possession, custody, or control that may be relevant to the matters described in Section II above. Each identified custodian is personally responsibl

1. Lorraine Okafor, Senior Vice President, Human Resources. Ms. Okafor is the primary custodian of HR policies, employee handbooks, training materials, employee complaints and grievances, personnel files, and any HR-related communications concerning the named plaintiffs, putative class members, Gavin Aldrich, and other employees relevant to this hold. Ms. Okafor is also responsible for compiling a complete list of al

2. Gregory Tanaka, Vice President, Legal & Compliance. Mr. Tanaka is the primary custodian of legal hold records, data loss prevention audit findings, compliance review documents, internal investigation files, and communications with outside counsel (including Calderwood & Harkness LLP and any other outside counsel engaged in connection with the matters described in Section II). Mr. Tanaka is the designated point of

3. Jonathan Mercer, President. Mr. Mercer is a custodian of executive-level communications regarding the October 2022 restructuring directive, termination decisions (including decisions relating to Gavin Aldrich), corporate strategy documents, and senior management communications relating to any of the matters subject to this hold.

4. Celine Arroyo, Director of Production Operations. Ms. Arroyo is a custodian of production schedules, call sheets, wrap reports, daily production logs, staffing records, crew schedules, and facility-level operational documents across all fourteen (14) California-based production units and all seven (7) AMA California facilities.

5. Dwayne Prescott, Vice President of Unscripted Programming. Mr. Prescott is a custodian of show unit operations documents, creative development communications, and personnel-related communications within the Unscripted Programming Division. Mr. Prescott served as Gavin Aldrich's direct supervisor prior to Mr. Aldrich's termination and is a custodian of communications regarding Mr. Aldrich's performance, conduct, an

6. Karen Fong, Payroll Manager. Ms. Fong is a custodian of payroll records, TimeTrack Pro system configuration records, meal period automatic deduction settings, Missed Meal Attestation feature logs, wage statements, and all other payroll-related data and documentation for California-based non-exempt employees.

7. All Direct Supervisors of Named Plaintiffs. All individuals who served as direct supervisors of Marisol Fuentes, Derek Halloran, Yesenia Padilla, or Gavin Aldrich during their respective periods of employment at AMA are also identified as custodians under this hold. Lorraine Okafor is directed to compile a complete and accurate list of all such supervisors and to provide that list to Gregory Tanaka no later than N

VI. IMMEDIATE ACTION REQUIRED Upon receipt of this notice, you must take the following actions immediately: A. Do NOT Delete, Discard, or Destroy. You must not delete, discard, throw away, shred, or otherwise destroy any documents or ESI that may fall within the scope of this Litigation Hold, regardless of whether you believe them to be duplicative, outdated, or unimportant. This prohibition applies to both paper and

VII. PENALTIES FOR NON-COMPLIANCE You should be aware that the failure to comply with this Litigation Hold may result in severe and irreversible consequences for Aurelius Media Americas Inc., including but not limited to the following: • Court-Imposed Sanctions. Courts have broad authority to impose sanctions on parties who fail to preserve relevant evidence, including the exclusion of evidence, the striking of plead

VIII. DURATION This Litigation Hold will remain in effect until you receive written notice from the Legal & Compliance Department that the hold has been lifted, in whole or in part. You should not assume that this hold has been lifted or modified based on informal communications, the passage of time, the resolution of one or more of the matters described in Section II, or any other circumstance. Only a formal written

IX. ACKNOWLEDGMENT AND CLOSING INSTRUCTIONS Please acknowledge your receipt of this Litigation Hold Notice by taking one of the following actions within three (3) business days of receipt: (a) Sign and return the attached Litigation Hold Acknowledgment Form (Document 4 / Acknowledgment Template) to Gregory Tanaka via interoffice mail or hand delivery; or (b) Send an email to Gregory Tanaka at gtanaka@aureliusmedia.co