Contract analysis

I. Engagement Overview This memorandum sets forth the proposed staffing plan, preliminary budget estimate, and immediate action items for the above-referenced matter. The purpose of this memorandum is to provide you, as billing partner, with a comprehensive overview of anticipated resource requirements, professional fee estimates, and projected expenses so that we may establish appropriate billing protocols, communic

II. Matter Complexity and Anticipated Phases This matter presents substantial complexity across multiple dimensions: the number of individual defendants, the coordinated nature of their departure, the potential involvement of a well-financed private equity sponsor, the volume of proprietary information at risk, and the need for emergency equitable relief in a highly fact-intensive setting. To structure our staffing a

III. Proposed Staffing Plan The staffing plan set forth below is designed to provide the depth of coverage necessary for a complex, multi-phase engagement while maintaining cost efficiency. Given the emergency timeline for Phase 2 and the volume of work required across all phases, I propose a core team of four timekeepers: two partners and two associates. If additional resources become necessary — for example, if exp

IV. Estimated Expenses and Disbursements In addition to professional fees, the engagement will generate significant out-of-pocket expenses and third-party vendor costs. All expenses will be billed to the client at cost in accordance with the engagement letter and the firm's standard billing practices. The principal categories of anticipated expenses and their estimated ranges are set forth below. A. Forensic Technolo

I. Expenses Summary Table Midpoint estimate: approximately $308,600 (calculated as the simple average of the low and high estimates for each category, summed across all categories, and rounded for convenience).

V. Total Preliminary Budget Estimate Combining the professional fee estimates set forth in Section III with the expense estimates set forth in Section IV, the total preliminary budget for the engagement is as follows: Several important qualifications apply to this estimate: First, the estimate assumes that the matter proceeds through the emergency TRO/preliminary injunction litigation phase and resolves through negot

VI. Billing and Administrative Notes The following billing and administrative protocols will apply to this engagement: • Matter Number: 1038-00006. All timekeepers should use this matter number for all time entries and expense charges related to this engagement. • Billing Partner of Record: Renata Vasquez (Los Angeles office). All invoices will be issued under your name as billing partner, and you will have primary r

VII. Anticipated Opposing Counsel As of the date of this memorandum, opposing counsel has not been identified for any of the defendants. • Individual Defendants (Rathore Group): Counsel for the eight individual defendants has not yet been identified. Based on the nature and seniority of the departing employees, we expect the individual defendants to retain experienced Delaware-based litigation or employment counsel,

VIII. Immediate Next Steps and Action Items The following action items require immediate attention and should be commenced without delay:

1. Crawford: Conduct initial strategy call with Theresa Yun-Park and Roland Ashby to confirm the factual background, obtain copies of all eight employment agreements and related documents, and discuss CRH's litigation objectives and settlement parameters. This call is scheduled for February 19, 2025.

2. Underwood / Archer: Upon receipt of the employment agreements, begin a comprehensive review of all eight agreements. Prepare the covenant summary memorandum and comparative chart identifying the scope, duration, geographic reach, and enforceability of each restrictive covenant provision. Target completion: February 22, 2025.

3. Crawford: Finalize the engagement of Pinnacle Forensics LLC (Dr. Rajiv Anand) for forensic imaging and cloud log analysis. Target: February 20, 2025. Finalize the engagement of Aurelian Investigations Group Inc. (Sandra Fielding) for investigation of the coordinated departure. Target: February 21, 2025.

4. Crawford (with Underwood): Prepare and issue a litigation hold notice for distribution to all relevant CRH custodians (including Ms. Yun-Park, Mr. Ashby, Mr. Cho, IT personnel, and any other employees with potentially relevant documents or communications). The litigation hold must be issued promptly to preserve CRH's obligations and to establish CRH's good faith in connection with any discovery disputes. Target: F

5. Underwood / Archer: Draft cease-and-desist letters to all eight departing employees (individually addressed), to Verdana Commerce Group, Inc., and to Greystone Capital Partners, LP. The letters should be reviewed by Crawford prior to issuance. Target for partner review: February 24, 2025. Target for issuance: February 25, 2025.

6. Underwood: Begin legal research on Delaware restrictive covenant enforceability standards, including the current state of the law on reasonableness of scope, duration, and geographic restrictions; the blue-pencil doctrine; the inevitable disclosure doctrine under Delaware law; and DUTSA trade secret requirements (including the definition of "trade secret," the "reasonable measures" prong, and available remedies).

7. Crawford: Coordinate with CRH (through Ms. Yun-Park or her designee) regarding injunction bond sourcing. Confirm that CRH has identified Broadview Surety Corp. as the preferred surety provider, and initiate the application process so that the bond can be posted promptly upon the filing of the TRO motion.

8. Vasquez: Establish all billing codes, complete matter setup in the firm's practice management system, and implement the budget tracking protocols described in Section VI above. Confirm that the billing rates reflected in this memorandum are accurate and consistent with the rates set forth in the engagement letter. Closing Renata, I would appreciate your confirmation of the staffing plan set forth above, including