Contract analysis

I. PURPOSE AND BACKGROUND This memorandum sets forth the forensic collection protocol, custodian list, data sources, date ranges, and search-term parameters for the collection of electronically stored information ("ESI") in connection with Calderwood & Harkness LLP's ("C&H") independent privileged workplace investigation conducted at the direction of the Board of Directors of Aurelius Global Media Group PLC ("AGMG").

II. SCOPE OF COLLECTION A. General Scope The forensic collection authorized by this memorandum shall encompass all ESI from identified custodians who are employed by, or were formerly employed by, Aurelius Pacific Studios Inc. that is relevant to the investigation of the allegations of sexual harassment, retaliation, and hostile work environment against Marcus Hale. The scope of collection is intentionally broad at t

III. CUSTODIAN LIST A. Identified Custodians (9 Total) The following table sets forth the nine (9) identified custodians for the forensic collection. Each custodian is assigned a priority level that reflects the anticipated relevance of their data to the investigation and dictates the order of collection. Priority 1 custodians are the subject of the investigation and the primary complainants; Priority 2 custodians ar

IV. DATA SOURCES The following data sources have been identified for collection. Linden Forensics shall collect ESI from each of the sources described below for each identified custodian, unless otherwise specified. A. Email. The primary source of ESI for collection is the Outlook / Exchange email accounts maintained by APS for all nine (9) custodians. APS's corporate email is hosted on APS corporate email servers ma

V. DATE RANGE Primary Date Range The primary date range for the forensic collection is January 1, 2019 through May 3, 2023 (the date on which Marcus Hale's access to APS systems was suspended). This date range shall apply to all nine (9) identified custodians, subject to the adjustments noted below. The rationale for this date range is as follows: January 1, 2019 corresponds to the period immediately preceding Marcus

VI. SEARCH-TERM PARAMETERS The following search terms and parameters shall be applied to the collected ESI to identify documents and communications potentially responsive to the investigation. These terms are organized by category and are intended to be applied in combination using Boolean logic, as described in Section VI.F below. A. Name and Entity Terms The following name and entity terms shall be included in the

VII. COLLECTION METHODOLOGY AND TECHNICAL REQUIREMENTS A. Forensic Imaging All collections shall be performed using forensically sound methods that preserve the integrity, authenticity, and metadata of the collected ESI. The following specific requirements apply: (i) Write-blocking for physical devices. All forensic imaging of physical devices (including mobile devices, laptops, and any external storage media) shall

VIII. COLLECTION SCHEDULE The forensic collection shall be conducted over a three (3) day period according to the following schedule: May 10, 2023 (Day 1): On-site collection at APS headquarters, 3200 West Alameda Avenue, Suite 400, Burbank, California 91505. Day 1 activities shall include: • Initial coordination meeting with APS IT personnel (facilitated by Victor Gallegos); • Commencement of email server exports fo

IX. CONFIDENTIALITY AND PRIVILEGE PROTECTIONS The confidentiality and privilege protections governing this engagement are of paramount importance and must be strictly observed by all Linden Forensics personnel at all times. All data collected, processed, stored, and delivered by Linden Forensics in connection with this engagement is subject to the protections of the attorney-client privilege and the work-product doct

X. COORDINATION WITH UK COUNSEL It is noted for the record that AGMG's UK corporate counsel, Pendleton & Warwick LLP, located at 20 Fenchurch Street, 8th Floor, London EC3M 3BY, United Kingdom, has been consulted regarding cross-border privilege protocols applicable to this investigation. Pendleton & Warwick has advised on the intersection of US attorney-client privilege and work-product protections with UK legal pro

XI. POINTS OF CONTACT The following individuals are designated as points of contact for purposes of this engagement. All communications regarding the forensic collection should be directed to the appropriate contact as indicated below. Linden Forensics shall confirm the name, direct telephone number, and email address of its designated Engagement Manager to Devon Archer no later than May 9, 2023. All substantive comm

XII. RESERVATION OF RIGHTS Calderwood & Harkness LLP, as directing counsel for this investigation, reserves the right to modify this forensic collection protocol at any time and from time to time as the investigation progresses and as the factual record develops. Modifications may include, without limitation: (a) Adding additional custodians to the custodian list, or removing custodians whose data proves to be not re