Contract analysis

1. Purpose of This Letter We write to provide you with a comprehensive status update on the contested probate proceeding captioned above during the current dormant period. As you are aware, the matter has been in standstill since the execution of the Settlement Standstill Agreement on April 28, 2023, pursuant to which all litigation deadlines have been tolled and the parties have refrained from filing new motions or

2. Current Status of the Proceeding 2.1 Procedural Posture To orient this discussion, we begin with a brief recapitulation of the procedural history of this matter. Your late husband, Teodoro R. Fonseca, passed away on September 3, 2022. Mr. Fonseca died intestate — that is, without a valid last will and testament. Upon his passing, you retained Calderwood & Harkness LLP to represent your interests as surviving spous

3. Summary of Legal Fees and Costs 3.1 Fees Billed Total fees billed by Calderwood & Harkness LLP through September 30, 2024, are $487,250.00. These fees have been calculated in accordance with the billing rates established in our engagement letter dated October 12, 2022, which are as follows: We note that billing activity has been substantially reduced during the dormant period under the Settlement Standstill Agreem

4. Recommendation — Standstill Renewal #3 4.1 Proposed Terms After careful consideration of the current posture of the case, the interests of the estate, and the relative costs and benefits of the available options, we recommend that you authorize the execution of a Third Amendment to the Settlement Standstill Agreement, extending the standstill period from its current expiration date of October 28, 2024, to February

5. Options Upon Standstill Expiration While we recommend renewal of the standstill as discussed in Section 4 above, we believe it is prudent to provide you with an overview of the options that will be available upon the eventual expiration of the standstill — whether that occurs on February 28, 2025 (the proposed new expiration date), or at some subsequent date. 5.1 Option A — Further Renewal The parties may agree to

6. Upcoming Action Items and Next Steps Based on the foregoing, the following action items require your attention in the near term:

1. Execute the Third Amendment. Please review the enclosed form of Third Amendment to the Settlement Standstill Agreement, sign where indicated, and return the executed copy to our office no later than October 25, 2024. As noted above, the current standstill period expires on October 28, 2024, and the Third Amendment must be executed by all parties before that date to ensure an uninterrupted standstill.

2. Remit Outstanding Balance. Please remit the outstanding balance of $38,590.00 at your earliest convenience. Payment may be made by check payable to "Calderwood & Harkness LLP Client Trust Account" and mailed to our office, or by wire transfer to the account specified on the enclosed invoice. Please contact Patricia Dunmore at (213) 555-7218 if you require wire transfer instructions.

3. Schedule a Strategy Discussion. We recommend scheduling a telephone call or in-person meeting in late January or early February 2025 to discuss strategy for the period following the February 28, 2025, standstill expiration. At that time, we will be able to assess whether the Contestants appear receptive to settlement discussions, whether a second mediation session is advisable, or whether the time has come to prep

4. Updated Valuations. We recommend coordinating with Pinnacle West Appraisal Group LLC regarding whether updated valuations of the decedent's membership interests in Lumiére Canyon Studios LLC and Pacific Rim Narrative Partners LLC may be advisable. The most recent internal valuation of Lumiére Canyon Studios is dated December 31, 2021 — nearly three years ago — and it is possible that the company's value has change

5. Monitor Estate Administration. We will continue to review the quarterly reports issued by Ashford Fiduciary Services Inc. and coordinate with Ridgeway Accounting Partners LLP to ensure that the estate's financial records remain accurate and current. We will promptly notify you of any developments or concerns arising from the estate administration.

7. Conclusion In summary, we recommend that you authorize the execution of the Third Amendment to the Settlement Standstill Agreement, extending the standstill period to February 28, 2025. This course of action preserves the status quo, avoids the substantial costs of litigation reactivation, and maintains the informal settlement channel that may ultimately lead to a negotiated resolution of this proceeding on terms