Contract analysis

I. Purpose and Context of This Letter This letter confirms the terms and scope of Ashford Fiduciary Services Inc.'s ("Ashford") appointment as neutral administrator of the Estate of Teodoro R. Fonseca (the "Estate"), pursuant to the Stipulation for Appointment of Neutral Administrator filed with the Los Angeles County Superior Court on March 22, 2023, and entered by the Court in the above-referenced probate proceedin

II. Background on the Estate By way of background, Teodoro R. Fonseca passed away on September 3, 2022, without a will (intestate). Ms. Fonseca, as the surviving spouse, filed a Petition for Letters of Administration with the Los Angeles County Superior Court on October 5, 2022, seeking appointment as administrator of the Estate. The Contestants filed an initial objection to the petition on November 14, 2022, challen

III. Identification of Estate Assets Under Administration The following assets constitute the probate estate and fall within the scope of Ashford's administration. This summary is based on the Preliminary Estate Asset Summary prepared by our firm (a copy of which is enclosed), as supplemented by preliminary appraisals and account records obtained to date. A. Real Property The Estate includes two parcels of real prope

1. Beverly Hills Residence: 1847 Coldwater Canyon Drive, Beverly Hills, CA 90210. This property serves as the primary family residence. The estimated fair market value of this property is $8,450,000, based on a preliminary appraisal conducted by Pinnacle West Appraisal Group LLC dated February 10, 2023.

2. Malibu Beach House: 27100 Pacific Coast Highway, Malibu, CA 90265. This property is a secondary residence. The estimated fair market value of this property is $6,200,000, also based on a preliminary appraisal by Pinnacle West Appraisal Group LLC dated February 10, 2023. Title records for both properties are currently held by Coastline Title & Escrow Co. The primary contact at Coastline is Andrea Solis, whose offic

1. Lumiére Canyon Studios LLC. The decedent held a fifty percent (50%) membership interest in Lumiére Canyon Studios LLC, a California limited liability company (California Secretary of State Filing No. 200906410337). The principal office of Lumiére Canyon Studios LLC is located at 4200 West Olive Avenue, Burbank, CA 91505. Based on an enterprise value of approximately $31,600,000 as of December 31, 2021, the estimat

2. Pacific Rim Narrative Partners LLC. The decedent held a thirty-five percent (35%) membership interest in Pacific Rim Narrative Partners LLC, a California limited liability company (California Secretary of State Filing No. 201518720492). The managing member of Pacific Rim Narrative Partners LLC is Victor Sandoval, whose office is located at 8455 Beverly Boulevard, Suite 310, Los Angeles, CA 90048. Based on approxim

1. Brokerage Account (Account No. ending in -4782): Approximate balance as of the date of death (September 3, 2022): $5,120,000.

2. Personal Checking Account (Account No. ending in -3091): Approximate balance as of the date of death: $342,000.

3. Money Market Account (Account No. ending in -6155): Approximate balance as of the date of death: $1,875,000. The Estate's designated relationship manager at Veltara Basin Bank, N.A. is Franklin Ybarra, located at 700 South Hope Street, Los Angeles, CA 90017. Mr. Ybarra has been notified of Ashford's appointment and is prepared to work with you in facilitating account access and reporting. We ask that you coordinat

1. Term Life Insurance Policy: Meridian Mutual Life Insurance Co., Policy No. GH-TL-2019-05582, with a death benefit of $3,000,000. The named beneficiary is Marguerite D. Fonseca. This policy is payable directly to the named beneficiary as a non-probate asset.

2. Whole Life Insurance Policy: Commonwealth Fidelity Assurance Corp., Policy No. GH-WL-2014-01247, with a death benefit of $2,000,000. The named beneficiary is Marguerite D. Fonseca. This policy is likewise payable directly to the named beneficiary as a non-probate asset. The total non-probate life insurance proceeds are $5,000,000. A separate Petition for Preliminary Distribution of Non-Probate Assets was filed wit

IV. Scope of Ashford's Administrative Duties This Section sets forth in greater detail the scope and nature of Ashford's duties as neutral administrator, consistent with the terms of the Stipulation and the Court's order. A. Asset Preservation and Management Ashford's primary obligation is to maintain and preserve all probate estate assets in their current condition, to the greatest extent practicable, pending resolu

V. Fee Arrangement and Cost-Sharing The fee arrangement for Ashford's services as neutral administrator has been established by the Stipulation. This Section confirms the applicable fees and the agreed-upon cost-sharing structure. A. Monthly Administration Fee Ashford's monthly administration fee shall be $8,500 per month, as stipulated in the Stipulation for Appointment of Neutral Administrator filed and entered on

VI. Quarterly Reporting Requirements Timely and transparent reporting is essential to the proper administration of the Estate and to the maintenance of confidence among all parties. Accordingly, we request that Ashford provide quarterly reports to both Calderwood & Harkness LLP and Brennan, Ortega & Saldívar LLP, containing the information described below. A. Financial Report Each quarterly report shall include a com

VII. Pending Claims Against the Estate For Ashford's awareness and for the purpose of ensuring proper administration, we briefly identify below certain pending claims that have been asserted by the Contestants against the Estate. These claims are disputed by Ms. Fonseca and remain unresolved. We bring them to your attention so that Ashford is informed, but we emphasize that Ashford should not take any action with res

1. Isabela C. Fonseca-Greer — Promissory Note Claim. Isabela C. Fonseca-Greer has asserted a claim based on a promissory note dated January 15, 2020, in the principal amount of $1,200,000, plus accrued interest at 3.5% per annum, payable to Amber Light Documentary Films LLC, an entity in which Ms. Fonseca-Greer holds a controlling interest. Ms. Fonseca disputes the validity and enforceability of this claim. The total

2. Nicolás R. Fonseca — Educational Expense Reimbursement Claim. Nicolás R. Fonseca has asserted a claim in the amount of $387,500 for educational expense reimbursement, based on an alleged oral promise by the decedent to reimburse him for graduate school tuition and related costs. Ms. Fonseca disputes this claim, both as to the existence of the alleged oral promise and as to the amount claimed. We reiterate that Ash

VIII. Points of Contact To ensure efficient and orderly communication during the course of the administration, the following individuals are designated as the primary points of contact: For Ms. Fonseca (Petitioner): Elliot Nguyen, Lead Associate Calderwood & Harkness LLP 350 South Grand Avenue, Suite 4800 Los Angeles, CA 90071 Telephone: (213) 555-7200 With copies on all substantive correspondence to: Howard Quinn, R

IX. Request for Confirmation We respectfully request that Mr. Whitmore, on behalf of Ashford Fiduciary Services Inc., confirm in writing his agreement with the terms set forth in this letter, including, without limitation: (a) The scope of administrative duties as described in Section IV; (b) The fee arrangement and cost-sharing structure as described in Section V; (c) The quarterly reporting requirements and schedul

X. Confidentiality Reminder Finally, we wish to remind Ashford that the underlying dispute between Ms. Fonseca and the Contestants is subject to confidentiality provisions, including those contained in the Court's mediation order, those contemplated in the pending settlement discussions, and those to be set forth in the anticipated Settlement Standstill Agreement currently being negotiated between counsel. Ashford an

1. Copy of Stipulation for Appointment of Neutral Administrator (filed March 22, 2023)

2. Preliminary Estate Asset Summary prepared by Calderwood & Harkness LLP cc: Marguerite D. Fonseca (via email) Elliot Nguyen, Calderwood & Harkness LLP Grace Nakamura, Calderwood & Harkness LLP Damian R. Ortega, Brennan, Ortega & Saldívar LLP (via email and first class mail) Dennis Chua, Ridgeway Accounting Partners LLP (via email) Asset Category | Estimated Value Beverly Hills Residence | $8,450,000 Malibu Beach Ho