Contract analysis

I. Introduction and Purpose of Letter I am writing in my capacity as Responsible Partner on the above-referenced matter to provide you with a comprehensive status report on the confirmation and enforcement proceedings regarding the Final Award issued by the American Arbitration Association on August 22, 2025 (AAA/ICDR Case No. 01-24-0003917). As you know, the Final Award was rendered in Halcyon Semiconductor AG's ("H

II. Summary of Case Posture A. Petition to Confirm Arbitration Award On October 14, 2025, we filed a Petition to Confirm Arbitration Award on behalf of Halcyon in the United States District Court for the Central District of California. The case has been assigned to the Honorable Robert G. Kendrick, United States District Judge, and has been designated Case No. 2:25-cv-08742-RGK-PLA. Magistrate Judge duties have been

III. Key Upcoming Deadlines The following is a summary of the key deadlines and anticipated procedural milestones in the near term: We note that under 9 U.S.C. § 12, a petition to confirm an arbitration award must be filed within one year of the date the award is made. Our filing on October 14, 2025 is well within the statutory period, the Award having been issued on August 22, 2025. Conversely, Meridian's three-mont

IV. Asset Preservation and Enforcement Concerns A. Risk of Asset Dissipation Our team, led by Patrick Gallagher and Simone Laroche, has been conducting a thorough analysis of Meridian's financial condition and asset base in order to assess collectability of the Award and to identify risks that may warrant emergency relief. Based on Meridian's most recently available financial disclosures, filed with the California Se

V. Budget Update A. Fee Arrangement Recap Pursuant to the engagement letter dated September 30, 2025, the applicable hourly billing rates for this matter are as follows: • Partners: $1,350 per hour • Senior Associates: $875 per hour • Associates: $725 per hour The matter budget estimate provided in the engagement letter for the confirmation and initial enforcement phase of this engagement (exclusive of any appellate

VI. Commercial and Supply-Chain Coordination We understand from our initial engagement discussions that the termination of the Distribution Agreement on March 15, 2024 required Halcyon to restructure its distribution arrangements for the U.S. market. As the enforcement proceedings advance, they may involve discovery requests, document production, or other interactions that touch upon Meridian's current business opera

VII. Next Steps Summary The following is a summary of the immediate action items arising from this status report:

1. Await Meridian's Cross-Motion to Vacate. Meridian's cross-motion to vacate the Award is due on or before November 13, 2025. We will promptly circulate a copy of the motion and supporting papers to you upon receipt.

2. Prepare and File Opposition Brief. Upon receipt of Meridian's cross-motion, we will prepare and file Halcyon's opposition brief and the Declaration of Hon. Gerald M. Osterhaus (Ret.) addressing the evident-partiality allegations. We will circulate drafts for your review before filing.

3. File Ex Parte Application for TRO (Upon Client Authorization). Upon receipt of your authorization, we will file the ex parte application for a temporary restraining order and order to show cause re preliminary injunction for asset preservation. We recommend filing within seven to ten business days and request your prompt response on this item.

4. Continue Asset Analysis and Enforcement Strategy Investigation. We will continue our investigation into the Brindoval National Bank lien priority, Mr. Calloway's personal assets, encumbrances on the Ontario real property, and the feasibility of domesticating any California judgment in Delaware or other relevant jurisdictions.

5. Request Hearing Date and Expedited Schedule. We will notify the Court of readiness for hearing on the Petition to Confirm and the anticipated cross-motion to vacate, and request that Judge Kendrick set the matter on an expedited schedule in light of the asset-dissipation concerns.

6. Client to Replenish Retainer and Confirm TRO Authorization. We request that Halcyon replenish the retainer to $150,000 (supplemental payment of approximately $135,700) and confirm authorization for the asset-preservation motion at your earliest convenience.

7. Client to Coordinate with Marcus Pfeiffer. We ask that Dr. Reinhardt coordinate with Marcus Pfeiffer, SVP, Global Sales, regarding the commercial and supply-chain matters described in Section VI above, and ensure that relevant market intelligence is channeled to our litigation team on a timely basis.

VIII. Closing We remain confident in the strength of the Petition to Confirm and in the weakness of the vacatur arguments that Meridian is expected to advance. The Final Award was issued unanimously by a distinguished panel of arbitrators, was grounded in a thorough evidentiary record, and applied well-established principles of California contract law. The legal standard for confirmation is highly deferential, and th