Contract analysis

1. Matter Overview This memorandum sets forth a comprehensive closing summary of the representation of Marguerite D. Fonseca in the matter captioned Fonseca v. Rennick et al., filed in the Superior Court of the State of California, County of Los Angeles, Case No. 23STCV01897. The matter has been resolved by settlement, and the file is being closed as of the date of this memorandum. Client: Marguerite D. Fonseca, an i

2. Engagement Team The following Calderwood & Harkness professionals were assigned to this matter: Partner Samuel Eklund supervised all strategic decisions, attended the full-day mediation session on May 19, 2023, and served as the primary relationship partner for the client throughout the engagement. Partner Linda Osei served as billing partner, reviewed all invoices, and managed the client's retainer account. Assoc

3. Opposing Counsel Firm: Hargrove, Pettit & Sun LLP 800 South Figueroa Street, Suite 3100 Los Angeles, CA 90017 Lead Partner: Elaine Chow Associate: Marcus Webb Hargrove, Pettit & Sun LLP appeared on behalf of Desmond R. Rennick. The firm's initial response to our pre-litigation demand letter was received on November 2, 2022 and was signed by Ms. Chow. Ms. Chow and Mr. Webb handled all aspects of the defense, includ

4. Key Consultants and Third Parties The following consultants and third parties played significant roles in the matter: Forensic Accountant: Tillerman Forensic Advisory LLC 350 South Grand Avenue, Suite 1480 Los Angeles, CA 90071 Principal: Greta Sørensen, CPA, CFF Tillerman Forensic Advisory was retained by Calderwood & Harkness on behalf of Ms. Fonseca prior to the opening of this matter. Ms. Sørensen was engaged

5. Background Summary 5.1 The Partnership and Its Properties Coastal Meridian Productions LLP ("CMP") is a California limited liability partnership, EIN 83-2197644, formed on March 8, 2017. CMP's registered agent is Pacific Coast Registered Agents, Inc., located at 4200 Wilshire Blvd., Suite 610, Los Angeles, CA 90010. The partnership's principal office is located at 1140 N. La Brea Avenue, Suite 300, Los Angeles, CA

6. Procedural History / Timeline The following timeline summarizes the key events in the matter from the formation of the partnership through the execution of the settlement agreement:

7. Result Summary 7.1 Settlement Payment The parties agreed to a total settlement payment of $975,000, representing approximately 69.3% of the total claimed amount of approximately $1,407,589 (inclusive of estimated pre-judgment interest). The settlement amount is payable in two installments: First Installment: $600,000, due within fifteen (15) business days of the execution of the Settlement Agreement, which yields

8. Fee Summary The following table summarizes the total fees, costs, and net recovery in this matter: The total all-in client cost of $251,470 came in significantly below the estimated through-trial budget of $630,000, reflecting the efficient pre-trial resolution achieved through mediation. The Calderwood & Harkness professional fees of $148,500, combined with disbursements of $4,320, tracked closely to the pre-liti

9. Key Documents in File The following twelve documents are maintained in the matter file for Matter No. 1035-00004: (a) Engagement Letter — executed by Ms. Fonseca and Calderwood & Harkness LLP, dated October 10, 2022, setting forth the scope of the engagement, fee arrangements, and retainer terms. (b) Pre-Litigation Demand Letter to Rennick — dated October 10, 2022, sent to Desmond R. Rennick at 438 Georgina Avenue

10. Follow-Up Items The following items require attention after the date of this memorandum and should be tracked by the engagement team until completed:

1. Monitor Receipt of First Installment ($600,000). The First Installment is due by wire transfer within fifteen (15) business days of the execution of the Settlement Agreement, yielding a deadline of August 4, 2023. Upon confirmation of receipt, the Joint Stipulation for Dismissal with Prejudice should be filed promptly with the Court. If the First Installment is not received by the August 4 deadline, contact Hargro

2. Monitor Receipt of Second Installment ($375,000). The Second Installment is due on or before October 15, 2023. The same enforcement protocol applies: if payment is not received by the deadline, contact opposing counsel and advise the client of her enforcement rights.

3. File Joint Stipulation for Dismissal with Prejudice. Upon confirmation of receipt of the First Installment, file the Joint Stipulation for Dismissal with Prejudice with the Superior Court, County of Los Angeles, Case No. 23STCV01897.

4. Render Final Invoice. The remaining balance of approximately $77,820 (professional fees of $148,500 plus disbursements of $4,320, less the $75,000 initial retainer) should be invoiced to the client on the August 2023 billing cycle.

5. Deliver Executed Originals. Deliver executed originals of the Settlement Agreement and Mutual Release, the Restated Distribution Waterfall (Exhibit A), and the Second Amendment to the CMP Partnership Agreement to the client under separate cover.

6. Transfer File to Closed-Matter Storage. In accordance with the Firm's standard document-retention policy, the file should be transferred to closed-matter storage after all of the following conditions have been satisfied: (i) All settlement payments (First and Second Installments) have been confirmed received; (ii) The Joint Stipulation for Dismissal has been filed and the dismissal has been entered by the Court; a

11. Lessons and Notes The following observations are recorded for the benefit of the engagement team and the Firm's institutional knowledge: Value of Early Forensic Engagement. The early engagement of Tillerman Forensic Advisory — and in particular the retention of Greta Sørensen, CPA, CFF — was critical to building leverage throughout this matter. Ms. Sørensen's December 19, 2022 preliminary forensic accounting memo