Contract analysis

1. I am the Vice President of Unscripted Programming at Aurelius Media Americas Inc. ("AMA"). I have held this position since July 2020. Prior to my promotion to this role, I served as Senior Director of Development for AMA's Unscripted Programming Division from January 2018 through July 2020. In both capacities, I have been responsible for overseeing the creative development, production management, and strategic dir

2. During the entirety of my tenure as Vice President of Unscripted Programming, I reported directly to Gavin Aldrich ("Aldrich"), who served as Senior Vice President of Original Content and Executive Producer within AMA's Unscripted Programming Division. Specifically, I reported to Aldrich from the time I assumed the Vice President role in July 2020 until his termination from AMA on October 14, 2022. In this reporti

3. In my capacity as Vice President of Unscripted Programming, I am thoroughly familiar with the proprietary show concepts and format bibles developed by AMA's Unscripted Programming Division. Show format bibles are treated as highly confidential within AMA, and access to them is restricted to authorized personnel involved in the development and production process. A show format bible is a comprehensive document that

4. I am personally familiar with the three show format bibles that, as described in AMA's Cross-Complaint, Aldrich transmitted without authorization to Halcyon Creek Productions LLC ("Halcyon Creek"). Those three format bibles correspond to the show concepts known internally at AMA as "Apex Endurance," "The Remix," and "Untamed West." All three concepts were developed by AMA's in-house development team under Aldrich'

5. I am also familiar with the "Summit Challenge" franchise, which is AMA's flagship unscripted program. "Summit Challenge" has been in continuous production since 2019, and as of the date of this declaration, the program is currently in production on its fifth season. "Summit Challenge" generates approximately $42 million in annual revenue for AMA across domestic and international licensing, advertising revenue, and

6. The show format bibles for "Apex Endurance," "The Remix," and "Untamed West," as well as the sizzle reel for "Untamed West" and the "Summit Challenge" revenue model described above, were all stored on AMA's secure internal content management system, known internally as "AMA Vault." AMA Vault requires individual login credentials — including a unique username and password for each authorized user — and access is re

7. I am not aware of any legitimate business reason for Aldrich to have transmitted the show format bibles for "Apex Endurance," "The Remix," or "Untamed West," or the "Summit Challenge" revenue model, to Halcyon Creek Productions LLC, or to have transmitted any of these materials to his personal email account at galdrich.private@gmail.com. The transmission of show format bibles and revenue models to a third-party pr

8. I have known Nina Castellanos ("Castellanos"), the principal of Halcyon Creek Productions LLC, for approximately eight years. Castellanos was previously employed by AMA as a Director of Development from 2018 through January 2022. During her tenure at AMA, Castellanos worked within the Unscripted Programming Division and, in that capacity, worked closely with Aldrich. Based on my direct observations and my familiar

9. Halcyon Creek Productions LLC operates in the unscripted and reality television production space — the same market in which AMA competes for network and platform commissions, talent relationships, and advertising revenue. The unauthorized disclosure of AMA's show format bibles for "Apex Endurance," "The Remix," and "Untamed West," and especially the "Summit Challenge" revenue model, to a direct competitor in this