Contract analysis

I. Purpose This memorandum memorializes the opening of a new matter for the representation of Marguerite Delphine Fonseca (the "Client") in connection with a contested probate proceeding arising from the intestate death of her husband, Teodoro Raúl Fonseca (the "Decedent"), on September 3, 2022, in Los Angeles County, California. The Decedent died without a known valid will, trust, or other testamentary instrument, a

II. Client Information The following information has been gathered from the Client during the initial intake meeting held on October 7, 2022, at the firm's Los Angeles office, supplemented by publicly available records and documents provided by the Client. • Client Name: Marguerite Delphine Fonseca • Age: 54 • Residence: 1847 Coldwater Canyon Drive, Beverly Hills, California 90210 • Occupation: Chief Creative Officer

III. Decedent Information The following information concerning the Decedent has been gathered from the Client, publicly available records, and documents reviewed to date. • Full Legal Name: Teodoro Raúl Fonseca • Age at Death: 62 • Date of Death: September 3, 2022 • Place of Death: Beverly Hills, California • Cause of Death: Cardiac arrest. The death has been determined to be of natural causes. A certified copy of th

1. Rafael T. Fonseca, age 33, currently residing at 502 Olive Avenue, Unit 3, Burbank, California 91502. Rafael is employed as Vice President of Development at Crestline Media Group Inc. He is the eldest of the Decedent's children.

2. Isabela C. Fonseca-Greer, age 30, currently residing at 78 Eucalyptus Lane, Santa Monica, California 90402. Isabela is the principal of Amber Light Documentary Films LLC (California Secretary of State Filing No. 201912360185), a documentary production company. She is married; her spouse's surname is Greer.

3. Nicolás R. Fonseca, age 26, currently residing at 1190 Elm Street, Apartment 4B, Palo Alto, California 94301. Nicolás is currently enrolled as a graduate student. The specific institution and program of study are being confirmed but are understood to be at Stanford University. • Children of Current Marriage: The Client and the Decedent had no children together. • Business Interests: The Decedent held the following

IV. Proceeding Information The relevant procedural details of the probate proceeding are as follows: • Court: Los Angeles County Superior Court, Probate Division, Stanley Mosk Courthouse, 111 North Hill Street, Los Angeles, California 90012. • Case Number: 22STPB09714 • Filing: A Petition for Letters of Administration was filed by the Client, Marguerite D. Fonseca, on October 5, 2022, seeking appointment as administr

V. Matter Number and Engagement Team A. Matter Number This matter has been assigned firm Matter Number 1035-00005 in the firm's conflict and accounting systems. All time entries, cost disbursements, correspondence, and work product are to be charged and indexed to this matter number. B. Engagement Team The following attorneys have been assigned to the engagement team for this matter: The engagement team members bring

VI. Billing Arrangement The billing arrangement for this engagement is as follows, per the terms of the engagement letter executed by the Client on October 12, 2022: • Fee Structure: The firm will bill for its services on an hourly basis. The applicable hourly rates for the engagement team are as follows: • Partners: $975.00 per hour • Senior Associates (admitted 5+ years): $650.00 per hour • Associates (admitted few

VII. Summary of Estate Assets Based on information provided by the Client, publicly available records, and a preliminary review of available financial documentation, the following is a summary of the known estate assets as of the date of the Decedent's death, September 3, 2022. All valuations are preliminary estimates subject to formal appraisal and discovery. The engagement team should treat these figures as working

VIII. Client's Position on Asset Characterization The characterization of estate assets as community property or separate property is the central legal and factual issue in this matter. The Client's position is that all probate assets are community property, having been acquired during the marriage (June 14, 2008, through September 3, 2022) or substantially funded with community property funds during the marriage. Th

IX. Anticipated Contested Issues Based on information provided by the Client, preliminary intelligence regarding the contestants' likely positions, and the engagement team's analysis of the factual landscape, the following contested issues are anticipated. A. Premarital Agreement The Decedent's children are expected to assert the existence of a premarital agreement allegedly executed on or about May 30, 2008, approxi

X. Intestate Succession Framework Because the Decedent died without a valid will or trust, the distribution of the probate estate is governed by the intestate succession provisions of the California Probate Code. The applicable framework is as follows: Community Property — California Probate Code § 6401(a): The surviving spouse receives all of the community property of the decedent. This provision is unequivocal: if

XI. Key Third Parties and Professionals A. To Be Engaged or Contacted The following third-party professionals have been identified for potential engagement or contact in connection with this matter:

1. Business Appraiser — Pinnacle West Appraisal Group LLC Contact: Dr. Sandra Fujimoto, ASA, CVA Address: 4100 MacArthur Boulevard, Suite 200, Newport Beach, California 92660 Pinnacle West Appraisal Group LLC is being considered for retention to provide independent business valuations of Lumiére Canyon Studios LLC, the Decedent's 35% membership interest in Pacific Rim Narrative Partners LLC, and the IP portfolio (roy

2. Forensic Document Examiner — Brindoval Forensic Document Services LLC Contact: Dr. Elaine Prescott Address: 921 North La Brea Avenue, Suite 200, Los Angeles, California 90038 Brindoval Forensic Document Services LLC has been identified as a potential candidate for retention if the contestants produce the alleged premarital agreement or any other document whose authenticity is in question. Dr. Prescott is a board-c

3. Estate Accountant — Ridgeway Accounting Partners LLP Contact: Dennis Chua, CPA Address: 515 South Flower Street, Suite 3600, Los Angeles, California 90071 Ridgeway Accounting Partners LLP is to be engaged to prepare the estate inventory, assist with tax filings (including the estate tax return, if applicable, and the Decedent's final individual income tax return), and provide financial reconciliation and tracing a

4. Title Company — Coastline Title & Escrow Co. Contact: Andrea Solis Address: 9401 Wilshire Boulevard, Suite 720, Beverly Hills, California 90212 Coastline Title & Escrow Co. holds records and title insurance policies on both the Beverly Hills Residence and the Malibu Beach House. The engagement team should contact Ms. Solis to obtain copies of the title insurance policies, preliminary title reports, and chain-of-ti

5. Neutral Administrator (Potential) — Ashford Fiduciary Services Inc. Contact: Gerald Whitmore Address: 600 Wilshire Boulevard, Suite 1450, Los Angeles, California 90017 Ashford Fiduciary Services Inc. may be proposed as a neutral estate administrator if the parties are unable to agree on the Client's appointment as administrator of the estate, or if the court determines that a neutral administrator is appropriate g

1. Contestants' Counsel — Brennan, Ortega & Saldívar LLP Lead Attorney: Damian R. Ortega, Partner Associate: Lydia Kwan Address: 1900 Avenue of the Stars, Suite 2100, Los Angeles, California 90067 Brennan, Ortega & Saldívar LLP is a trusts and estates litigation boutique based in Century City. The firm is well-regarded in the Los Angeles legal community for its contested probate practice. Damian R. Ortega is a named

2. Contestants' Appraiser — Hargrove & Linden Appraisals Inc. Contact: Morton Linden, CFA, ASA Address: 2600 Michelson Drive, Suite 800, Irvine, California 92612 Hargrove & Linden Appraisals Inc. is anticipated to provide competing valuations of the business interests and other assets in the estate on behalf of the contestants. Morton Linden holds the Chartered Financial Analyst (CFA) and Accredited Senior Appraiser

XII. Initial Strategy Considerations and Immediate Action Items A. Immediate Priorities (Next 30 Days) The following action items are to be completed within the first thirty days of the engagement (by approximately November 12, 2022):

1. Veltara Basin Bank Account Freeze. Draft and send a letter to Franklin Ybarra, relationship manager at Veltara Basin Bank, N.A. (700 South Hope Street, Los Angeles, CA 90017), requesting an immediate freeze on all accounts held in the name of Teodoro R. Fonseca or in joint names with the Decedent, including the brokerage account (ending -4782), the checking account (ending -3091), and the money market account (end

2. PRNP Information Request. Draft and send a letter to Victor Sandoval, managing member of Pacific Rim Narrative Partners LLC, requesting: (a) confirmation of the Decedent's 35% membership interest; (b) a copy of the current operating agreement and any amendments thereto; (c) capital account statements from the inception of the fund through the date of death; (d) a complete distribution history; (e) the most recent

3. Life Insurance Claims. Advise the Client to submit death benefit claims to Meridian Mutual Life Insurance Co. (Policy No. GH-TL-2019-05582, $3,000,000 death benefit) and Commonwealth Fidelity Assurance Corp. (Policy No. GH-WL-2014-01247, $2,000,000 death benefit) through Paul Rennert at Garnet Hill Insurance Brokerage Inc. (1230 Rosecrans Avenue, Suite 400, Manhattan Beach, CA 90266). The Client should provide eac

4. Intestacy Rights Memorandum. Prepare an internal research memorandum analyzing the Client's rights under California Probate Code §§ 6400-6414, including a detailed discussion of the community property distribution rule (§ 6401(a)), the separate property distribution rules (§§ 6401(c), 6402), and the impact of various asset characterization scenarios on the Client's share of the probate estate. The memorandum shoul

5. Respond to Anticipated Objection. Monitor the court docket for Case No. 22STPB09714 for any filing by Brennan, Ortega & Saldívar LLP or by any of the contestants in response to the Client's Petition for Letters of Administration. The engagement team should establish a daily docket monitoring protocol and should prepare a response framework in advance so that a substantive response can be filed promptly once an obj

6. Retain Appraiser. Finalize the retention of Pinnacle West Appraisal Group LLC (Dr. Sandra Fujimoto) for the business valuation of Lumiére Canyon Studios LLC, the valuation of the Decedent's 35% membership interest in Pacific Rim Narrative Partners LLC, and the appraisal of the IP portfolio. The retention letter should define the scope of the engagement, the valuation date (September 3, 2022, date of death), the ap

7. Client Update. Prepare an initial case assessment letter to Ms. Fonseca summarizing the status of the matter, the anticipated contested issues, the immediate action items, and the next steps. The letter should be drafted in a clear, accessible manner and should avoid overly technical legal language where possible. The letter should also confirm the billing arrangement and provide an initial estimate of anticipated