Contract analysis

I. Interview Details A. Date, Time, and Location The interview of Jenna Morales was conducted on May 22, 2023, which constituted the first day of witness interviews in the independent investigation authorized by the People & Culture Committee and the Audit & Risk Committee of the Board of Directors of Aurelius Global Media Group PLC ("AGMG"). The interview took place at the Los Angeles office of Calderwood & Harkness

II. Background on Jenna Morales A. Employment History Ms. Morales's current title is Vice President of Development at Aurelius Pacific Studios Inc. ("APS"), the Los Angeles–based film and streaming content subsidiary of Aurelius Global Media Group PLC ("AGMG"). Ms. Morales has been employed by APS since March 2020, a period of approximately three years at the time of the interview. Ms. Morales reports directly to Mar

III. Summary of Allegations A. Overview Ms. Morales alleges that Marcus Hale, President of Aurelius Pacific Studios Inc., subjected her to unwanted sexual advances, sexually explicit comments, and unwelcome physical contact over a period spanning approximately September 2022 through March 2023. Ms. Morales characterized the conduct as a pattern of escalating harassment that began with comments about her appearance, p

IV. Filing of Formal Complaint Ms. Morales described the process by which she filed her formal complaint in detail: On April 18, 2023, Ms. Morales submitted a written complaint through the Meridian Compliance Solutions Ethics & Compliance Hotline, a third-party reporting mechanism maintained by APS and AGMG for the confidential submission of employee complaints regarding potential violations of company policy, includ

V. Morales's Knowledge of Other Complaints or Concerns Ms. Morales was asked whether she was aware of any other complaints, concerns, or incidents involving Marcus Hale and other employees, either at APS or elsewhere within the AGMG organization. Ms. Morales stated that she was aware of "rumors" circulating among female employees at APS that Hale had behaved inappropriately toward other women in the past. She describ

VI. Impact on Morales Ms. Morales described the significant personal and professional impact of Hale's conduct on her well-being. From an emotional standpoint, Ms. Morales stated that she has experienced substantial distress as a result of the harassment, including persistent anxiety, difficulty sleeping, and a general reluctance to attend work events, particularly those at which Hale might be present. She described

VII. Documentary Evidence Referenced During the interview, Ms. Morales referenced the following categories of documentary evidence relevant to her allegations:

1. Text message screenshots (3): Screenshots of three text messages sent by Marcus Hale to Ms. Morales, dated November 14, 2022, November 29, 2022, and December 8, 2022, respectively. These screenshots are preserved on Ms. Morales's personal phone. Ms. Morales stated that copies have been provided to her counsel, Sandra Reeves of Nakamura Reeves LLP, and will be produced to the investigation team through Ms. Reeves's

2. Contemporaneous journal entries: Ms. Morales stated that she maintained contemporaneous notes in a personal journal application on her phone regarding at least two incidents: the January 11, 2023 one-on-one meeting comment and the February 3, 2023 company dinner incident. She offered to produce these entries to the investigation team through her counsel.

3. Written hotline complaint: Ms. Morales's written complaint submitted on April 18, 2023, through the Meridian Compliance Solutions Ethics & Compliance Hotline, assigned case reference number MCS-1014-00001. A copy of this complaint was received by the investigation team from Victor Gallegos, VP of Human Resources at APS.

4. Demand letter from Sandra Reeves: The formal demand letter dated April 20, 2023, sent by Sandra Reeves of Nakamura Reeves LLP on behalf of Ms. Morales to Aurelius Pacific Studios Inc., alleging FEHA violations and demanding document preservation. A copy of this letter was received by the investigation team from Fiona Blackwood, General Counsel of AGMG.

5. Forensic collection data (Linden Forensics Group Inc.): Linden Forensics Group Inc. completed a forensic collection of electronic data from Hale's company-issued and, to the extent accessible, personal devices, as well as Ms. Morales's company-issued devices, during the collection period of May 10–12, 2023. The cross-referencing of Ms. Morales's account of text messages and other communications against the data re

VIII. Morales's Awareness of Applicable Policies Ms. Morales was asked about her familiarity with APS's policies regarding harassment, discrimination, and retaliation, as well as the formal complaint procedures available to employees. Ms. Morales stated that she was familiar with the APS Employee Handbook (California Supplement), which was most recently revised on March 15, 2022. She specifically identified her aware

IX. Demeanor and Credibility Observations The following observations regarding Ms. Morales's demeanor and credibility are noted for the investigation file: Ms. Morales was composed and articulate throughout the approximately three-hour-and-forty-five-minute interview. She answered questions directly and without evasion, and she demonstrated a clear understanding of the distinction between the information sought and t

X. Follow-Up Items The following action items were identified based on the interview with Ms. Morales:

1. Text message screenshots: Obtain copies of the three text message screenshots (dated November 14, November 29, and December 8, 2022) from Ms. Morales through Sandra Reeves / Nakamura Reeves LLP, pursuant to the agreed-upon production protocol.

2. Journal entries: Obtain copies of the contemporaneous journal entries referenced by Ms. Morales (relating to the January 11, 2023 meeting comment and the February 3, 2023 dinner incident) through her counsel.

3. Forensic cross-referencing: Cross-reference Ms. Morales's account of text messages sent by Hale with data collected by Linden Forensics Group Inc. from Hale's company-issued and personal devices during the May 10–12, 2023 collection period.

4. Corroborating witness interviews — February 3 dinner attendees: Interview the colleagues identified by Ms. Morales as having been seated nearby during the February 3, 2023 dinner incident, as well as any additional individuals with knowledge of the events described by Ms. Morales.

5. Interview of Claire Ngo: Interview Claire Ngo, Senior Director of Talent Relations at APS, regarding her separate but corroborating complaint filed on April 24, 2023. Interview currently scheduled for May 25, 2023.

6. Interview of Darren Whitfield: Interview Darren Whitfield, Senior Vice President of Physical Production at APS, regarding his reported concerns about Hale's treatment of women, including his comments at the January 23, 2023 leadership meeting. Interview currently scheduled for May 30, 2023.

7. Interview of Victor Gallegos: Interview Victor Gallegos, Vice President of Human Resources at APS, regarding his receipt and escalation of the hotline complaint (MCS-1014-00001), the handling of any prior complaints or concerns involving Hale, and APS's compliance with its own internal complaint procedures. Interview currently scheduled for June 1, 2023.

8. Interview of Marcus Hale: Schedule and conduct an interview of Marcus Hale, President of APS, currently on paid administrative leave. The interview is to be scheduled following negotiation of terms and logistics with Hale's personal counsel, Graham Thornfield of Thornfield & Associates LLP. Calderwood & Harkness's initial outreach letter to Mr. Thornfield was sent on May 19, 2023, and a response is pending as of t

9. APS Employee Handbook review: Review Sections 5.3 (Anti-Harassment & Anti-Discrimination Policy), 5.7 (Anti-Retaliation Policy), and 8.1 (Formal Complaint Procedures) of the APS Employee Handbook (California Supplement, revised March 15, 2022) for purposes of the compliance analysis component of the investigation.

10. Ongoing document review: Continue the review of the filtered document set (approximately 38,600 items as of May 15, 2023) for evidence corroborating or contradicting the allegations made by Ms. Morales and any other complainants or witnesses.

XI. Document Retention This memorandum constitutes privileged attorney work product prepared at the direction of counsel in connection with the independent workplace investigation authorized by the People & Culture Committee and the Audit & Risk Committee of the Board of Directors of Aurelius Global Media Group PLC. It reflects the mental impressions, conclusions, opinions, and legal theories of the attorneys involve