Contract analysis

1. Introduction and Purpose This firm represents the Board of Directors of Aurelius Global Media Group PLC ("AGMG"), a public limited company incorporated under the laws of England and Wales, in connection with an independent privileged workplace investigation (the "Investigation"). The purpose of this letter is to request that your client, Marcus Hale, participate in an interview as part of the Investigation, to out

2. Request to Schedule Interview of Marcus Hale Calderwood & Harkness LLP requests to interview Mr. Hale as part of the Investigation. The interview of Mr. Hale is an essential component of the Investigation. It represents a critical step in our fact-finding process and provides Mr. Hale with a meaningful opportunity to respond directly to the allegations that have been raised, to present his own account of the relev

3. Ground Rules for the Interview To ensure that the interview proceeds in an orderly, professional, and productive manner, we propose the following ground rules, which are consistent with prevailing standards for internal investigations of this nature. 3.1 Conduct of the Interview The interview will be conducted by Bernard Crawford, Partner, and Devon Archer, Senior Associate, of Calderwood & Harkness LLP. The inter

4. Corporate Representation Admonition (Upjohn Warning) At the outset of the interview, and before substantive questioning begins, Calderwood & Harkness will provide Mr. Hale with a standard corporate representation admonition. This admonition is sometimes referred to as an "Upjohn warning" or "corporate Miranda," and it is a routine and well-established component of interviews conducted in the course of corporate in

5. Written Position Statement Calderwood & Harkness acknowledges that Mr. Hale may wish to submit a written position statement or declaration in addition to or in connection with his participation in the interview. We welcome the submission of any such statement, and we will give it full and fair consideration as part of the Investigation record. If Mr. Hale elects to submit a written position statement, we request t

6. Administrative Leave Status We note that Mr. Hale has been on paid administrative leave from Aurelius Pacific Studios Inc. since May 3, 2023. During the period of administrative leave, Mr. Hale's access to company email, the company's Meridian Solutions workspace, and all other internal systems and platforms of AGMG and APS has been suspended. This administrative leave was imposed as a precautionary measure in con

7. Confidentiality Obligations The existence, subject matter, and status of the Investigation are confidential. We request that Mr. Hale and his counsel maintain strict confidentiality with respect to this letter, the scheduling and conduct of the interview, and all communications and materials exchanged in connection with the Investigation. In particular, Mr. Hale should not contact, directly or indirectly, any curr

8. Document Preservation Reminder We take this opportunity to remind Mr. Hale of his continuing obligation to preserve all documents, communications, and electronically stored information ("ESI") potentially relevant to the Investigation. As you may be aware, a litigation hold notice was issued by Aurelius Pacific Studios Inc. on May 2, 2023, and was delivered to Mr. Hale on that same date. The litigation hold remain

9. Response Requested We respectfully request that you respond to this letter no later than Friday, May 26, 2023, with the following: (a) Confirmation that Mr. Hale is willing to participate in the interview; (b) Mr. Hale's preferred date or dates for the interview from among the proposed options set forth in Section 2 above, or alternative dates if none of the proposed dates is available; and (c) Any preliminary que

10. Reservation of Rights Calderwood & Harkness, on behalf of AGMG and APS, expressly reserves all rights, remedies, privileges, and defenses available to AGMG and APS under applicable law, contract, and corporate governance instruments, including but not limited to the right to draw appropriate inferences in the event that Mr. Hale declines to participate in the interview, refuses to answer questions during the inte