Contract analysis

I. Upjohn Admonition and Preliminary Instructions At the outset of the interview, Devon Archer administered the standard Upjohn / corporate representation admonition consistent with the firm's template script that has been used throughout the course of this investigation, which commenced on May 22, 2023. The admonition was read from the firm's standard form and the following principal points were communicated to Whit

1. Calderwood & Harkness LLP represents Aurelius Global Media Group PLC ("AGMG") and its subsidiaries, including Aurelius Pacific Studios Inc. ("APS"), in connection with this internal investigation. Calderwood & Harkness LLP does not represent Whitcomb individually in any capacity.

2. The purpose of this interview is to gather facts relevant to the internal investigation being conducted at the direction of counsel for AGMG.

3. The interview is protected by the attorney-client privilege. That privilege belongs solely to the company — AGMG — and not to Whitcomb. The company, in its sole discretion, may choose to waive or assert the privilege, and may elect to disclose the contents of this interview to third parties, including regulators, government agencies, or other parties, without Whitcomb's consent.

4. Whitcomb was instructed not to discuss the substance of the interview, the questions asked, or the answers provided, with any other person, including current or former employees of AGMG, APS, or any affiliated entity.

5. Because Whitcomb is a former employee of APS, the admonition further clarified that Calderwood & Harkness LLP does not represent APS or AGMG in any capacity vis-à-vis Whitcomb, and that no attorney-client relationship exists or is being created between Calderwood & Harkness LLP and Whitcomb by virtue of this interview. Whitcomb was advised that she should not construe any statements made during the interview as le

6. Whitcomb was advised that her participation in this interview is entirely voluntary. As a former employee, she is under no obligation to participate and may decline to answer any question or terminate the interview at any time. Whitcomb verbally acknowledged her understanding of each of the foregoing admonitions. She confirmed that she understood that Calderwood & Harkness LLP does not represent her, that the priv

II. Background and Employment History Whitcomb provided the following background information regarding her employment with APS: Full Name: Serena Whitcomb Former Title: Executive Assistant to the President, Aurelius Pacific Studios Inc. Employment Dates: Approximately April 2019 through September 2021 Reporting Relationship: Whitcomb reported directly to Marcus Hale, President of Aurelius Pacific Studios Inc. Primary

III. Account of Inappropriate Conduct by Marcus Hale A. Nature and Timing of Alleged Inappropriate Comments Whitcomb stated that over the course of her employment, and particularly during the period of approximately early 2021 through her departure in September 2021, Hale made comments to her that she considered inappropriate, unwelcome, and inconsistent with a professional working relationship. She described these c

IV. The July 2021 Informal Complaint A. Decision to Report Whitcomb stated that in approximately July 2021 — she could not recall the precise date but believed it was during the first or second week of July — she decided to raise her concerns about Hale's conduct with Victor Gallegos, Vice President of Human Resources at Aurelius Pacific Studios Inc. She stated that by that point, Hale's comments had become frequent

V. Circumstances of Whitcomb's Departure from APS A. Decision to Leave Whitcomb stated that she made the decision to resign from Aurelius Pacific Studios Inc. in approximately August 2021, approximately one month after her complaint to Gallegos, with her departure becoming effective in September 2021. She described multiple factors contributing to her decision to leave: • Ongoing discomfort in her working relationshi

VI. Whitcomb's Knowledge of Other Complaints or Conduct Whitcomb was asked whether she was aware of conduct by Hale similar to that she described, directed at other employees during her tenure at APS from April 2019 through September 2021. Whitcomb stated that she had observed Hale making what she described as "flirtatious" comments to other female employees on occasion during her time at APS. She stated that these c

VII. Documentation and Records Whitcomb was asked about any documentary evidence she may possess relating to the conduct described in this memorandum or to her complaint to Gallegos. Whitcomb stated that she did not retain any written documentation of the inappropriate comments made by Hale. She stated that she did not keep contemporaneous notes, a journal, or any other written record memorializing the specific comme

VIII. Credibility and Demeanor Observations Whitcomb presented as composed, measured, and forthcoming throughout the duration of the interview. She answered questions directly and did not appear evasive or reluctant to discuss the matters at issue. Her demeanor was calm and professional, and she maintained consistent eye contact and engagement throughout the videoconference session. Her account was internally consist

IX. Documents Referenced or Identified No documents were produced by Whitcomb in connection with this interview. As noted in Section VII above, Whitcomb does not possess any documentary evidence related to the matters discussed. The following APS and AGMG policies and documents are referenced in this memorandum for cross-referencing purposes: • APS Employee Handbook (CA Supplement), revised March 15, 2022 — Section 5

X. Follow-Up Items No further follow-up with Whitcomb is anticipated at this time. The interview is considered complete, and Whitcomb's account has been fully documented in this memorandum. Whitcomb's account will be cross-referenced with documentary evidence obtained during the forensic collection phase of the investigation. In particular, to the extent any electronic communications between Whitcomb and Gallegos reg