Contract analysis

I. Cross-Claims and discovery Status A. Amended Cross-Complaint AMA filed its original Cross-Complaint on January 20, 2023, asserting four causes of action against Plaintiff Gavin Aldrich ("Aldrich" or "Plaintiff"): (1) Breach of Employment Agreement, specifically the confidentiality provisions set forth in Section 9.4 of the parties' Employment Agreement dated March 15, 2021 (the "Agreement"); (2) Misappropriation o

II. Related Class Action AMA brings to the Court's attention a related action pending in this courthouse: Fuentes v. Aurelius Media Americas Inc., Case No. 22STCV38214, which has been consolidated with Case No. 22STCV39501 and is assigned to Hon. Raymond Escobedo, Department 34. The Fuentes class action involves materially different legal theories and facts from the Aldrich matter presently before this Court. Specifi

III. Mediation Proposal The parties are amenable to mediation of the Aldrich dispute. Counsel for AMA and counsel for Plaintiff have discussed mediation in general terms and agree that it is a productive avenue for resolution of this matter. AMA, however, respectfully proposes that mediation be scheduled after the completion of the following milestones, which AMA believes are necessary to ensure that mediation is con

1. Completion of the deposition of Gavin Aldrich, which is currently noticed for May 22, 2023. The Aldrich deposition is critical to AMA's evaluation of the case, as it will provide direct testimony on the key factual disputes underlying both Plaintiff's claims and AMA's cross-claims.

2. Resolution of the pending Motion to Compel Further Responses (hearing scheduled for May 19, 2023). The outcome of this motion will determine whether AMA obtains documents and communications that are central to its claims and that will materially affect AMA's assessment of the case for purposes of settlement discussions.

3. Progress toward resolution of the related class action, Fuentes v. Aurelius Media Americas Inc., Case No. 22STCV38214. As discussed in Section II above, AMA anticipates that the class certification briefing and hearing will be completed by mid- to late summer 2023. The resolution or advancement of the class action will bear on the broader landscape of AMA's employment litigation exposure and will enable AMA to ass

IV. Request for Further Status Conference AMA respectfully requests that the Court set a further status conference for July 2023 to address the following matters: • The status of discovery, including the outcome of the pending Motion to Compel Further Responses and any additional discovery disputes that may arise in the interim; • The scheduling of mediation and the selection of a mediator; and • Any other matters th