Contract analysis

I. Background and History of the Standstill By way of background, and for the sake of a complete record, we briefly recite the procedural history relevant to the Standstill Agreement and its prior renewals. The Standstill Agreement was executed on April 28, 2023, following the parties' first mediation session, which took place on April 12, 2023, before the Honorable Constance Adler (Ret.) of the Westside Dispute Reso

II. Proposal for Third Amendment — Key Terms We propose the following terms for the Third Amendment to the Settlement Standstill Agreement: (a) Extension of the Standstill Period. The standstill period would be extended from its current expiration date of October 28, 2024, through and including February 28, 2025. This represents a period of approximately four months, which is shorter than the six-month increments uti

III. Rationale for Continued Extension Ms. Fonseca believes that a further extension of the standstill period is in the mutual interest of all parties, and she has instructed us to convey the following considerations in support of the proposed Third Amendment. First, the parties have continued to engage in productive, if incremental, informal settlement discussions since the inception of the standstill period. While

IV. Logistics and Execution In order to facilitate your review and the timely execution of the proposed Third Amendment, we have enclosed with this letter a draft of the Third Amendment to the Settlement Standstill Agreement. The enclosed draft tracks the format and structure of the First Amendment and the Second Amendment, with appropriate modifications to reflect the proposed February 28, 2025 expiration date and t

V. Reservation of Rights Ms. Fonseca expressly reserves all of her rights, claims, remedies, and defenses in the probate proceeding, In re Estate of Teodoro R. Fonseca, Deceased, Los Angeles County Superior Court, Case No. 22STPB09714. Nothing in this letter, the enclosed draft Third Amendment to the Settlement Standstill Agreement, or any prior or future communications between the parties or their counsel in connect