Dear Philippa and Gregory,

From: Renata Vasquez <rvasquez@calderwoodharkness.com>
To: Philippa Cartwright <pcartwright@aureliusmedia.com>
Cc: Bernard Crawford <bcrawford@calderwoodharkness.com>
Date: Thu, 15 Feb 2024 03:45:00 -0000
Subject: Engagement Closure Confirmation and Summary of Outcomes — C&H Matter No. 1017-00004

Dear Philippa and Gregory,

I am pleased to confirm that Calderwood & Harkness LLP's engagement on behalf of Aurelius Media Americas Inc. under Matter No. 1017-00004 is formally closed effective today, February 15, 2024. Both matters within the scope of our engagement have been fully resolved, and I wanted to provide this summary communication as our definitive closing record.

**Summary of Outcomes**

| Matter | Resolution | Amount | Status |
|---|---|---|---|
| *Fuentes v. AMA* (Class Action, Case No. 22STCV38214) | Court-approved class settlement | $14,750,000 GSA | Final Approval Order entered Feb. 9, 2024 |
| *Aldrich v. AMA* (Executive Dispute, Case No. 22STCV41087) | Confidential settlement | $2,350,000 + 10,200 RSUs accelerated | Dismissed with prejudice Jan. 29, 2024 |
| **Total** | | **$17,100,000** | **Both matters fully resolved** |

**Financial Summary**

| Item | Amount |
|---|---|
| Total claimed exposure | $42,750,000 (combining $38.6M class + $4.15M Aldrich) |
| Total resolution value | $17,100,000 (40.0% of claimed exposure) |
| EPL carrier contribution (Pemberton Mutual Assurance Co.) | $9,250,000 |
| AMA self-funded (settlements) | $7,850,000 ($5,500,000 class + $2,350,000 Aldrich) |
| C&H fees and expenses | $3,279,700 (4.9% under budget of $3,450,000) |
| Total AMA out-of-pocket (all-in: settlements + defense costs) | ~$11,130,000 |

**Key Deliverables — Sent Under Separate Cover**

For your reference, the following materials have been or are being transmitted separately:

- **Post-Settlement Compliance Recommendations** (dated February 14, 2024) — including meal and rest break policy revisions, timekeeping system modifications, and restrictive covenant best practices
- **Document Retention Recommendations Post-Settlement** (dated February 12, 2024) — outlining retention obligations and suggested protocols following resolution of both matters
- **Final Billing Summary and Fee Reconciliation** (dated February 15, 2024) — reflecting the complete fee and expense accounting for the engagement

We encourage you to review each of these carefully, particularly the compliance recommendations, as timely implementation will meaningfully reduce the risk of similar claims going forward.

**Closing**

On behalf of the entire Calderwood & Harkness team — Bernard Crawford, Devon Archer, Nadia Petrov, and myself — I want to express our sincere gratitude for the trust you and the Aurelius Media leadership team placed in us throughout this engagement. These were complex, high-exposure matters, and we are genuinely proud of the outcomes achieved — resolving combined claimed exposure of nearly $43 million for approximately 26 cents on the dollar when measured against AMA's actual out-of-pocket costs.

We remain fully available should any post-resolution matters arise, whether related to compliance implementation, restrictive covenant audits, or future employment litigation needs. Please do not hesitate to reach out at any time.

It has been a privilege to serve as your counsel on these matters. We look forward to continuing the relationship.

With warm regards,

**Renata Vasquez** | Partner
Calderwood & Harkness LLP
777 South Flower Street, Suite 4200 | Los Angeles, CA 90017
T: (213) 555-7200 | rvasquez@calderwoodharkness.com