Contract analysis

1. Advance Written Notice of Specific Allegations Mr. Hale requests that Calderwood & Harkness provide him, through undersigned counsel, with a reasonably detailed written summary of the specific allegations to be addressed during the investigative interview. This summary should be provided no fewer than ten (10) business days prior to the scheduled interview date. At a minimum, the written summary should identify: (

2. Limitation on Interview Duration Mr. Hale requests that the investigative interview be limited to a single session not to exceed four (4) hours in duration, inclusive of any breaks taken during the session. This investigation involves serious allegations against a senior executive in the entertainment industry. Mr. Hale's career, livelihood, and personal reputation are directly at stake. While Mr. Hale is prepared

3. Presence of Personal Counsel The undersigned, Graham Thornfield, Founding Partner of Thornfield & Associates LLP, will attend the investigative interview as Mr. Hale's personal counsel. Mr. Hale's participation in the interview is conditioned upon counsel being permitted to be present in the room at all times during the interview session. Mr. Hale further requests that counsel be permitted to confer privately with

4. Right to Submit a Written Position Statement Mr. Hale requests that he be afforded the right to submit, through counsel, a comprehensive written position statement setting forth his detailed response to the allegations under investigation. This request is an essential component of a fair investigative process. An interview, by its nature, is conducted at the direction of the questioner; a written position statemen

5. Scope of Questioning Mr. Hale requests that the investigative interview be limited in scope to the specific allegations identified in the complaints of Jenna Morales, Claire Ngo, and Darren Whitfield, together with matters directly related thereto. The investigation was commissioned to address specific complaints by specific individuals; it should not be permitted to become a roving inquiry into every aspect of Mr

6. Document Access Mr. Hale requests that he be provided, through counsel, with copies of any documents that the investigation team intends to show, reference, or question Mr. Hale about during the interview at least five (5) business days prior to the scheduled interview date. As noted above, Mr. Hale's access to all company systems—including his company email account, the Aurelius Pacific Studios Meridian Solutions

7. Confidentiality and Non-Disclosure Mr. Hale acknowledges that this investigation is privileged and confidential and that the attorney-client privilege and work product protections associated with the investigation belong exclusively to Aurelius Global Media Group PLC. Mr. Hale does not claim any such privilege as his own and will respect the confidentiality of the investigative process. In return, Mr. Hale request

8. No Adverse Inference Mr. Hale requests written confirmation from Calderwood & Harkness that no adverse inference will be drawn from any of the following: (a) any invocation by Mr. Hale of his right to consult privately with counsel during breaks in the interview; (b) any request by Mr. Hale or his counsel for a break during the interview; or (c) any decision by Mr. Hale, on the advice of counsel, not to answer a s

9. Interview Location and Logistics Mr. Hale confirms that the proposed interview location at Calderwood & Harkness's Los Angeles office, 1999 Avenue of the Stars, Suite 2800, Los Angeles, California 90067, is acceptable. With respect to the interview date, Mr. Hale requests that the date be set in a manner that allows for full compliance with the advance-notice and document-access timelines requested above. Specific

10. Reservation of Rights Mr. Hale expressly and comprehensively reserves all of his rights, including but not limited to any and all rights arising under or in connection with: (a) his Employment Agreement with Aurelius Pacific Studios Inc. dated January 7, 2019, as amended, including any provisions relating to termination, compensation, benefits, indemnification, and dispute resolution; (b) the California Fair Empl