Contract analysis

I. Interview Overview Witness: Cameron Briggs, Senior Vice President of Production, Aurelius Pacific Studios Inc. Date of Interview: June 8, 2023 Location: Calderwood & Harkness LLP, Los Angeles Office, 1999 Avenue of the Stars, Suite 2800, Los Angeles, California 90067 Interviewer(s): Nadia Petrov, Associate, Calderwood & Harkness LLP. Devon Archer, Partner, Calderwood & Harkness LLP, was unavailable for this interv

II. Witness Background Full Name: Cameron Briggs Title: Senior Vice President of Production, Aurelius Pacific Studios Inc. ("APS") Office Location: APS Headquarters, 3200 West Alameda Avenue, Suite 400, Burbank, California 91505 Reporting Relationship: Briggs stated that he reports directly to Marcus Hale, President of Aurelius Pacific Studios Inc. Briggs confirmed that he is one of nine (9) Senior Vice Presidents wh

III. Circumstances of the Project Reassignment A. Notification of Reassignment Briggs stated that on or about February 6, 2023, he was called into a meeting with Marcus Hale in Hale's office at the APS Burbank headquarters. Briggs stated that the meeting was not previously scheduled and that he received a call from Hale's executive assistant asking him to come to Hale's office, which he did within approximately fifte

IV. January 23, 2023 Leadership Meeting Briggs confirmed that he attended the leadership team meeting on January 23, 2023. The meeting took place at the APS Burbank headquarters and was attended by Marcus Hale, Darren Whitfield, Briggs, and several other SVPs in Hale's direct-report group. Briggs stated that the meeting covered a range of routine production and operational topics, including slate updates, budget revi

V. Briggs's Observations Regarding Hale's Conduct Generally A. Interactions with Female Employees Briggs was asked whether he had personally observed any conduct by Marcus Hale toward female employees that Briggs considered inappropriate or concerning. Briggs stated that he had not witnessed any conduct that he would characterize as sexual harassment. However, Briggs provided the following additional context. Briggs

VI. Briggs's Observations Regarding Whitfield Briggs was asked for his assessment of Darren Whitfield's professional capabilities and performance, particularly in connection with Project Meridian and Project Halcyon. Briggs stated that Whitfield is a capable and experienced production executive with a strong track record at Aurelius Pacific Studios. Briggs stated he was "surprised" by the reassignment of Project Meri

VII. Briggs's Interactions with Hale Regarding the Investigation Briggs stated that following Marcus Hale's placement on paid administrative leave, effective May 3, 2023, Briggs received no further communications from Hale regarding any subject, whether related to the investigation, to ongoing APS business, or to personal matters. Briggs stated he had not spoken with Hale — by phone, email, text message, or in person

VIII. Documents Referenced During the course of the interview, Briggs was shown several documents and asked to confirm their authenticity and to provide any additional context or recollection. The documents shown to Briggs included the following:

1. Email from Marcus Hale to Cameron Briggs, dated February 6, 2023. This email directed Briggs to assume oversight of Project Meridian and Project Halcyon, effective immediately. Briggs confirmed that he received this email on or about February 6, 2023, following his in-person meeting with Hale that same day. Briggs noted that the email was brief and contained no stated justification for the reassignment beyond the

2. Email from Marcus Hale to Darren Whitfield, dated February 6, 2023, on which Briggs was copied. This email directed Whitfield to transition all project files, production schedules, vendor contracts, and related materials for Project Meridian and Project Halcyon to Briggs. Briggs confirmed that he was copied on this email and received it on or about February 6, 2023. The email was similarly brief and did not contai

IX. Additional Matters At the conclusion of the substantive interview, Briggs was asked several additional questions. Briggs was asked whether he had any concerns about participating in the investigation or any fear of retaliation — whether from Hale, from other members of APS leadership, or from any other source — as a result of his cooperation with the investigation. Briggs stated that he did not have any such conc

X. Assessment and Notes (Counsel's Internal Observations) The following section contains counsel's internal assessments, mental impressions, and analytical observations regarding the interview. This section is protected attorney work product and reflects the thought processes and strategic evaluations of counsel. It should be treated with the highest degree of confidentiality and is intended solely for use by the Cal