Contract analysis

I. Upjohn Admonition At the outset of the interview, Devon Archer administered the standard Upjohn / corporate representation warning to Darren Whitfield. Specifically, Whitfield was advised of the following: (a) Calderwood & Harkness LLP represents Aurelius Global Media Group PLC ("AGMG") and its subsidiaries, including Aurelius Pacific Studios Inc. ("APS"). The firm does not represent Whitfield in his individual ca

II. Background and Employment History Darren Whitfield provided the following background information at the beginning of the interview. Full Name: Darren James Whitfield Age: 47 Current Title: Senior Vice President of Physical Production, Aurelius Pacific Studios Inc. Employer: Aurelius Pacific Studios Inc., 3200 West Alameda Avenue, Suite 400, Burbank, California 91505 Employment Start Date: September 2017 Reporting

III. Working Relationship with Marcus Hale Whitfield provided the following account of the evolution of his working relationship with Marcus Hale over the period of Hale's tenure as President of APS. Whitfield stated that when Hale became President in January 2019, the transition from Gregory Felton's leadership was smooth. Whitfield described Hale as initially presenting as a strong operational leader with a clear v

IV. Observations of Hale's Conduct Toward Female Employees A. General Observations Whitfield described a pattern of conduct by Hale that he began to notice with increasing frequency from approximately mid-2022 forward. Specifically, Whitfield stated that he observed Hale making comments about the physical appearance of female employees on multiple occasions. These comments were made in informal settings, including af

V. The January 23, 2023 Leadership Meeting Whitfield provided a detailed account of a leadership team meeting held on January 23, 2023, at the Aurelius Pacific Studios headquarters located at 3200 West Alameda Avenue, Burbank, California. This meeting is significant to the investigation because it is the occasion on which Whitfield states he first raised concerns about Hale's conduct with Hale directly, in the presen

VI. Retaliatory Reassignment of Project Meridian and Project Halcyon A. Background on the Projects Whitfield provided background information regarding two high-profile production projects that he had been overseeing as part of his SVP of Physical Production portfolio: Project Meridian and Project Halcyon. Whitfield described these two projects as the largest and most significant active productions under his direct su

VII. Decision to Come Forward Whitfield explained that despite the reassignment of his projects and his growing concern about Hale's conduct, he did not initially file a formal complaint with Human Resources or through the AGMG Ethics & Compliance Hotline. Whitfield stated candidly that he feared further retaliation from Hale. Given that the reassignment had already demonstrated Hale's willingness to take adverse pro

VIII. Awareness of Prior Complaints or Incidents When asked whether he was aware of any prior complaints, formal or informal, regarding Marcus Hale's conduct, Whitfield stated the following. Whitfield recalled hearing a rumor — which he could not attribute to a specific source or conversation — that a former executive assistant to Hale had "some kind of issue" with Hale and subsequently left the company in approximat

IX. Relevant Documents Referenced or Identified by Whitfield During the course of the interview, Whitfield referenced or identified the following documents as potentially relevant to the investigation:

1. Email from Marcus Hale to Darren Whitfield, dated on or about February 6, 2023, confirming the reassignment of Project Meridian and Project Halcyon to Cameron Briggs, SVP of Production. Whitfield stated that he retained a copy of this email in his work email account and may also have forwarded a copy to his personal email for safekeeping. Whitfield stated the email was brief, approximately three to four sentences,

2. Meeting minutes or written records of the January 23, 2023 leadership meeting. Whitfield stated that he was not aware of any meeting minutes, written summary, or other contemporaneous documentation of the January 23 leadership meeting that would reflect his comments regarding Hale's conduct or Hale's response. He stated that leadership meetings at APS were not typically minuted.

3. Additional emails, calendar entries, and documents. Whitfield stated that he would make available to the investigation team any additional emails, calendar entries, text messages, or other documents in his possession that are relevant to the reassignment of Project Meridian and Project Halcyon, his interactions with Hale during the relevant period, or his observations of Hale's conduct toward female employees. Whi

X. Whitfield's Current Status and Concerns Whitfield confirmed that he remains employed at Aurelius Pacific Studios Inc. in his role as Senior Vice President of Physical Production as of the date of this interview. He has not been terminated, placed on leave, or subjected to any further formal adverse employment action since the reassignment of Project Meridian and Project Halcyon in February 2023. Whitfield noted th

XI. Interviewer Assessment and Notes Demeanor and Credibility. Throughout the interview, Whitfield presented as forthcoming, composed, and detailed. He provided specific dates, sequences, and contextual information without hesitation and without the need for significant prompting. His account appeared well-organized and was delivered in a manner that reflected careful recollection rather than scripted preparation. Wh

XII. Distribution and Privilege Reminder This memorandum is to be maintained in the privileged investigation file for Calderwood & Harkness LLP Matter No. 1017-00005. All copies — including electronic copies, printed copies, and any notes or summaries derived from this memorandum — are subject to the attorney-client privilege and the work-product doctrine and must be treated accordingly. Distribution of this memorand