Contract analysis

I. Overview and Deposition Logistics The deposition of Ava Lin, Senior Analyst at Grizzly Peak Research LLC ("GPR"), was taken on August 29, 2024, at the offices of Caldwell, Tseng & Barrow LLP, located at 555 California Street, Suite 3100, San Francisco, California 94104. The deposition commenced at approximately 9:00 a.m. and concluded at approximately 5:15 p.m., with customary breaks for lunch and short recesses,

II. Witness Background and Role at Grizzly Peak Research LLC A. Professional Background Ava Lin identified herself as a Senior Analyst at Grizzly Peak Research LLC, with offices located at 44 Maiden Lane, 7th Floor, San Francisco, California 94108. She holds the title of Senior Analyst and confirmed that she served as co-author of all three published GPR reports concerning Redstone Gaming Corp. that are at issue in t

III. Report 1 — "House of Cards: Redstone Gaming's Manufactured Earnings" (February 7, 2024) A. Genesis and Research Process Lin testified that she began conducting research on Redstone Gaming Corp. in approximately late 2023 or early January 2024, at the direction of Fenchurch. She stated that Fenchurch identified RGC as a potential research target based on what he described as "anomalies" in the company's revenue g

IV. Report 2 — "Rigged Reels: How Redstone's Slot Software Cheats the Regulators" (February 14, 2024) A. The RNG-Manipulation Allegation Report 2, published one week after Report 1, comprised 36 pages and advanced a separate and distinct category of allegations against RGC. The report alleged that RGC had manipulated its proprietary random-number-generator ("RNG") software used in its slot-machine gaming systems in o

V. Report 3 — "Double Down on Fraud: Redstone's Related-Party Shell Game" (February 21, 2024) A. The Related-Party / Vermilion Holdings Allegation Report 3, published on February 21, 2024, was the final of the three GPR reports on Redstone Gaming Corp. At 29 pages, it was the shortest of the three reports. Its central allegation was that RGC's Chief Executive Officer, Marcus J. Calloway, had engaged in undisclosed re

VI. Post-Publication Events and Lin's Awareness A. Regulatory Investigations Mr. Espinoza questioned Lin regarding her awareness of regulatory developments that followed the publication of the three GPR reports. Lin confirmed that she became aware the U.S. Securities and Exchange Commission ("SEC") opened an informal inquiry into RGC's financial reporting in March 2024, following the publication of the GPR reports. S

VII. Impeachment and Credibility Observations A. Inconsistencies with Fenchurch Testimony Lin's deposition testimony is materially inconsistent with the testimony provided by Tobias Fenchurch during his deposition on August 20, 2024. Specifically, Fenchurch testified that he relied on Lin's analysis and professional judgment in deciding to publish the three reports and that Lin did not raise any significant objection

VIII. Key Takeaways and Litigation Implications A. Evidentiary Value for Actual Malice Lin's deposition testimony provides powerful evidentiary support for RGC's claim that GPR published its reports with actual malice — that is, with knowledge that the allegations were false or with reckless disregard for their truth or falsity. Three categories of evidence merit particular emphasis: First, the Meridian Solutions mes

IX. Exhibit List — Deposition Exhibits Referenced The following deposition exhibits were marked and used during the examination of Ava Lin on August 29, 2024:

X. Distribution and Confidentiality Notice This memorandum constitutes privileged attorney work product prepared in anticipation of litigation within the meaning of California Code of Civil Procedure § 2018.030 and the federal work-product doctrine established in Hickman v. Taylor, 329 U.S. 495 (1947). It reflects the mental impressions, conclusions, opinions, and legal theories of counsel and is entitled to the high