Contract analysis

1. Purpose of This Letter and Identification of Counsel We write to inform you that Calderwood & Harkness LLP ("C&H") has been retained by Thornwick Medical Research Institute ("TMRI") to conduct an independent workplace investigation into formal grievances filed by multiple employees of TMRI's Biomedical Engineering Laboratories. The engagement between C&H and TMRI was formalized on September 10, 2024, pursuant to t

2. Nature and Scope of the Investigation Between August 12, 2024 and September 4, 2024, five current employees of TMRI filed formal written grievances pursuant to TMRI Employee Handbook § 7.3, which sets forth the "Grievance and Complaint Procedure" applicable to all TMRI personnel. Each of these grievances was submitted in writing, consistent with the requirements of that policy, and each was received and processed

1. Retaliation. Multiple grievants allege that employees who reported safety concerns or raised compliance issues were subjected to adverse employment actions, including reassignment to less desirable shifts, exclusion from research projects, reduction in laboratory access privileges, and other forms of professional marginalization. These allegations potentially implicate the Massachusetts Whistleblower Protection Ac

2. Hostile Work Environment. Grievants allege a pattern of conduct that created a hostile, intimidating, or offensive work environment within the Biomedical Engineering Laboratories. Specific allegations include, but are not limited to, verbal intimidation and berating of staff in the presence of colleagues; discriminatory scheduling practices that disproportionately burdened certain employees on the basis of protect

3. Safety-Protocol Violations. Grievants allege that, under your direction or with your knowledge and acquiescence, certain safety protocols were circumvented or not enforced within Laboratory Units B-1 through B-4. Specific allegations include failures to require the use of OSHA-mandated personal protective equipment as required under 29 C.F.R. § 1910.132 et seq., as well as lapses in biohazard-containment protocols

4. Falsification or Alteration of Records. Grievants allege that certain safety-incident reports and laboratory-notebook entries were falsified, altered, backdated, or otherwise manipulated. The investigation will examine the integrity of records maintained within the Biomedical Engineering Laboratories, including the chain of custody and version history of relevant documents, to determine whether any improper altera

3. Paid Administrative Leave After careful consideration and in consultation with TMRI's General Counsel and Vice President of Human Resources, TMRI has determined that it is appropriate and necessary to place you on paid administrative leave effective September 18, 2024, pending the completion of the investigation. This decision has been made to preserve the integrity of the investigative process, to protect the rig

4. Obligation to Cooperate Under TMRI Employee Handbook § 7.3, all employees of TMRI, regardless of position or seniority, are required to cooperate fully and in good faith with workplace investigations conducted by or at the direction of TMRI. This obligation encompasses the following: (a) Participating in investigative interviews when requested by the investigation team, providing truthful, complete, and candid res

5. Right to Retain Personal Legal Counsel We wish to reiterate that C&H represents TMRI and does not represent you individually. You are hereby advised that you have the right to retain personal legal counsel of your own choosing and at your own expense in connection with this investigation. The decision whether to retain personal counsel is entirely yours to make, and TMRI will not draw any adverse inference from yo

6. Document Preservation Obligations A formal litigation-hold memorandum was issued by TMRI General Counsel Elena Graff on September 13, 2024, and you should have received or will shortly receive a copy of that memorandum. The litigation-hold memorandum sets forth TMRI's document-preservation requirements in detail. This letter serves as an additional and independent reminder of your personal obligation to preserve a

7. Confidentiality This investigation is being conducted as a privileged matter at the direction of TMRI. You are directed to maintain strict confidentiality regarding all aspects of the investigation. Specifically, you are directed to refrain from: (a) Discussing the substance of the investigation, including the allegations described in this letter or any details that may come to your attention during the investigat

8. Anti-Retaliation Notice TMRI strictly prohibits retaliation against any individual who files a grievance, participates in or cooperates with a workplace investigation, provides information or testimony in good faith, or exercises rights protected by law or TMRI policy. This prohibition applies to all forms of retaliation, whether direct or indirect, and encompasses adverse employment actions, threats, intimidation

9. Investigation Process and Expected Timeline For your information, we provide the following overview of the investigation process and anticipated timeline: The investigation will include, at a minimum, the following activities: (a) Interviews of the individuals who filed the formal grievances (the "complainants"); (b) One or more interviews of you, as the respondent named in the grievances; (c) Interviews of other

10. Point of Contact The primary point of contact for all matters relating to this investigation is: Nadia Petrov Associate, Labor & Employment Calderwood & Harkness LLP One Federal Place, Suite 3200 Boston, MA 02110 Telephone: (617) 555-0184 Email: npetrov@calderwoodharkness.com All communications from you, or from your personal legal counsel if retained, regarding the investigation — including questions, scheduling

1. I am required to cooperate fully with the investigation, including participating in interviews, responding to information requests, and otherwise conducting myself in a manner consistent with the obligations described in the letter.

2. I am required to preserve all documents and electronically stored information that may be relevant to the investigation, as described in the letter and in the litigation-hold memorandum issued by TMRI General Counsel.

3. I am required to maintain the confidentiality of the investigation as described in the letter.

4. I am required to comply with the terms and conditions of paid administrative leave as described in the letter.

5. Calderwood & Harkness LLP represents Thornwick Medical Research Institute and does not represent me personally. I understand that I have the right to retain personal legal counsel of my own choosing and at my own expense. Receipt of this letter and execution of this acknowledgment does not constitute an admission of any allegation described in the Investigation Notification Letter. ________________________________