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CONFIDENTIAL

NAKAMURA REEVES LLP Attorneys at Law

515 South Flower Street, Suite 3600 Los Angeles, California 90071 Telephone: (213) 555-4100 Facsimile: (213) 555-4101

Sandra Reeves, Partner Direct Dial: (213) 555-4118

Email: sreeves@nakamurareeves.com

July 7, 2023

VIA EMAIL AND U.S. MAIL

Bernard Crawford, Esq. Responsible Partner, Labor & Employment Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 2800 Los Angeles, California 90067

Re: Jenna Morales — Investigation into Allegations Against Marcus Hale, President, Aurelius Pacific Studios Inc. / Request for Interim Protective Measures

Dear Mr. Crawford:

I write on behalf of my client, Jenna Morales, Vice President of Development at Aurelius Pacific Studios Inc. ("APS" or the "Company"), in connection with the independent workplace investigation currently being conducted by your firm, Calderwood & Harkness LLP ("C&H"), at the direction of the Board of Directors of Aurelius Global Media Group PLC ("AGMG") into allegations of sexual harassment and retaliation against Marcus Hale, President of Aurelius Pacific Studios Inc.

As you are aware, your firm acknowledged by letter dated May 10, 2023, my firm's demand letter of April 20, 2023, and described the general scope and parameters of the investigation that C&H had been retained to conduct. Ms. Morales has cooperated fully with the investigation to date, including sitting for a comprehensive interview with your team on May 22, 2023, and she remains willing to continue her cooperation. This letter, however, addresses serious and growing concerns regarding the pace of the investigation and, more urgently, the need for immediate interim protective measures to safeguard Ms. Morales's employment status, professional standing, and well-being during and after the pendency of this matter.

I. Concerns Regarding the Pace of the Investigation

The investigation was formally opened on May 2, 2023 — now more than nine weeks ago. Ms. Morales's initial complaint, however, predates even that milestone. She filed her complaint via the Meridian Compliance Solutions Ethics & Compliance Hotline on April 18, 2023, and the matter was assigned case reference number MCS-2023-04871. That filing was made nearly eleven weeks ago as of the date of this letter.

Ms. Morales self-identified on April 19, 2023, at which time the complaint was escalated by Victor Gallegos, Vice President of Human Resources at Aurelius Pacific Studios Inc., to Fiona Blackwood, General Counsel of AGMG, and Patricia Sung, Chief People Officer of AGMG. Our firm sent its formal demand letter the following day, April 20, 2023, to Aurelius Pacific Studios Inc., setting forth detailed allegations of violations of the California Fair Employment and Housing Act, California Government Code sections 12940 et seq., and demanding both document preservation and appropriate remedial action. The demand letter was received and acknowledged by the Company's counsel.

Despite this timeline — and despite the seriousness of the underlying allegations — Ms. Morales has not been informed of any substantive findings, interim determinations, or anticipated timeline for the conclusion of the investigation. She has received no written or oral communication from C&H, from the Board, or from any representative of the Company regarding the status of the investigation since her interview on May 22, 2023. This silence, now extending for well over six weeks, is itself a source of significant professional and personal distress.

We acknowledge, of course, that C&H is conducting what we trust is a thorough and impartial investigation, and we do not suggest that corners should be cut in the service of expediency. Nevertheless, the passage of time without resolution — and, critically, without any interim communication regarding anticipated milestones — places Ms. Morales in a prolonged state of uncertainty and professional vulnerability. She is expected to continue performing at a high level in a workplace environment permeated by awareness of the investigation, while she herself has been afforded no assurance regarding her status or the outcome of the process she initiated.

California law imposes a clear obligation on employers to act with promptness. Under Government Code section 12940(k), employers are required to take immediate and appropriate corrective action in response to complaints of harassment and retaliation. The California Supreme Court has repeatedly emphasized that a "timely" investigation is a statutory requirement, not merely a best practice. See, e.g., Nazir v. Sterling Reach Holdings, Inc., 178 Cal. App. 4th 243, 288 (2009) (discussing the duty to investigate promptly and thoroughly). While we do not presently contend that the investigation has been unreasonably delayed such as to constitute a violation of these obligations, we wish to place on the record our concern that the current trajectory risks crossing that threshold if the matter continues without measurable progress or communication.

We further note that the seriousness of the allegations is underscored by the fact that Ms. Morales's complaint has been corroborated by at least two additional employees. Claire Ngo, Senior Director of Talent Relations at APS, filed her own complaint on April 24, 2023, describing separate incidents of harassment by Mr. Hale. Additionally, Darren Whitfield, Senior Vice President of Physical Production at APS, reported his own concerns regarding retaliatory conduct by Mr. Hale on April 26, 2023. The existence of multiple independent complaints involving the same alleged perpetrator — complaints that collectively describe a pattern of misconduct spanning multiple months and multiple settings — underscores the gravity of this matter and the urgency of its resolution.

II. Ms. Morales's Current Employment Situation and Ongoing Concerns

We are aware that Marcus Hale was placed on paid administrative leave on May 3, 2023, and that his access to company email, Meridian Solutions, and internal systems was suspended at that time. We appreciate that this step was taken promptly following the formal opening of the investigation, and we acknowledge it as an appropriate preliminary measure.

However, Mr. Hale's absence does not, by itself, resolve the concerns that Ms. Morales faces on a daily basis. She continues to work in an environment where the investigation remains unresolved and where awareness of its existence — and of her role as the complainant — has become increasingly widespread. Ms. Morales reports concerns that colleagues who are aware of the investigation may view her unfavorably, either as the individual responsible for the disruption caused by Mr. Hale's absence from his duties, or as a person whose professional judgment or motives may be questioned. She has observed what she perceives to be a cooling of professional relationships with certain colleagues who had previously been collaborative and supportive, and she is concerned that her career trajectory — including consideration for upcoming projects, promotion opportunities, and high-profile assignments — may be adversely affected as a consequence of having come forward.

These concerns are neither speculative nor trivial. The allegations in Ms. Morales's complaint describe a pattern of egregious conduct by Mr. Hale that warrants prompt protective action regardless of the investigation's final outcome. Specifically, the complaint details the following:

• Unwanted sexual advances by Mr. Hale directed at Ms. Morales from approximately September 2022 through March 2023, spanning a period of approximately seven months;

• Inappropriate conduct during the Vancouver production trip in October 2022, during which Mr. Hale made repeated personal and sexual overtures to Ms. Morales outside of professional settings, including at a private dinner on October 14, 2022, and at a hotel bar on October 15, 2022;

• Sexually suggestive text messages sent by Mr. Hale to Ms. Morales's personal mobile phone on November 14, 2022, November 29, 2022, and December 8, 2022, copies of which have been preserved and were provided to your firm during Ms. Morales's interview;

• Inappropriate comments made during a one-on-one meeting on January 11, 2023, in which Mr. Hale made remarks of a sexual nature regarding Ms. Morales's appearance and suggested that her career advancement would benefit from a closer personal relationship with him; and

• Unwanted physical contact at a company dinner on February 3, 2023, during which Mr. Hale placed his hand on Ms. Morales's lower back and upper thigh in the presence of colleagues, despite her visible discomfort and her prior express rejections of his advances.

Moreover, as detailed in her original complaint, Ms. Morales was subjected to retaliatory reassignment after she rejected Mr. Hale's advances. Specifically, she was removed from the high-profile "Meridian" development slate in March 2023 — a project to which she had been the lead development executive since its inception — and was reassigned to lower-priority projects without explanation or legitimate business justification. This reassignment occurred in the immediate aftermath of her most recent rejection of Mr. Hale's advances and, upon information and belief, at his direct instruction.

The foregoing allegations, taken together, describe precisely the type of serious, sustained, and retaliatory misconduct that California law requires employers to address with the utmost urgency and seriousness. The fact that the investigation remains pending does not relieve the Company or the Board of the obligation to take affirmative steps to protect Ms. Morales in the interim.

III. Specific Requests for Interim Protective Measures

In light of the foregoing, and in order to ensure that Ms. Morales's rights are adequately protected during the pendency of this investigation and beyond, we respectfully request that the following interim protective measures be implemented immediately:

A. Formal Written Anti-Retaliation Assurance. We request a formal written assurance, issued jointly by Aurelius Pacific Studios Inc. and Aurelius Global Media Group PLC, that Ms. Morales will not be subjected to any form of retaliation — including but not limited to adverse employment action, termination, constructive discharge, reassignment, demotion, reduction in responsibilities, exclusion from projects or meetings, negative performance evaluations, changes to her compensation or benefits, alteration of her reporting structure, social ostracism facilitated or tolerated by management, or any other action that could reasonably be perceived as retaliatory — as a consequence of having filed her complaint or cooperated with the investigation. This assurance should be memorialized in a written communication from an authorized representative of both entities and delivered to my office within the timeframe set forth in Section V below.

B. Preservation of Title, Responsibilities, Compensation, and Office Location. We request written confirmation that Ms. Morales's current title (Vice President of Development), reporting structure, job responsibilities, compensation (including base salary, bonus eligibility, and any other forms of remuneration), benefits, and office location will be preserved in their current form and will not be altered during the pendency of the investigation or in its aftermath without Ms. Morales's prior written consent. Any proposed changes to any aspect of Ms. Morales's employment terms should be communicated to this office in advance, together with a detailed statement of the business justification for such change, so that we may assess whether any such change is legitimate and non-retaliatory.

C. Designation of a Point of Contact for Ongoing Retaliation Concerns. We request that Aurelius Pacific Studios Inc. designate a specific individual — other than Victor Gallegos, Vice President of Human Resources, given his involvement as a witness in the investigation — to serve as a confidential point of contact to whom Ms. Morales may report any concerns about retaliation, hostile conduct, or other adverse treatment on an ongoing basis during and after the investigation. This individual should be sufficiently senior within the organization to take prompt remedial action if warranted and should have no personal involvement in the matters under investigation. We request that the identity and contact information of this designated individual be communicated to Ms. Morales and to this office in writing.

D. Reminder of Anti-Retaliation Policy to Relevant Personnel. We request that all senior leaders and employees who report to, interact regularly with, or supervise Ms. Morales be reminded, in writing, of the Company's anti-retaliation policy as set forth in the APS Employee Handbook, California Supplement, Section 5.7. This reminder should make clear that any retaliatory conduct directed at Ms. Morales — or at any other individual who has participated in or cooperated with the investigation — will be treated as a separate and independently actionable violation of Company policy warranting disciplinary action, up to and including termination. We request that a copy of this written reminder be provided to this office for our records.

E. Written Update on Investigation Timeline. We request a written update on the anticipated timeline for completion of the investigation and delivery of findings to the Board of Directors of AGMG. We understand that investigations of this nature require time and diligence, and we are not requesting that C&H disclose the substance of its findings or compromise the integrity of its process. However, Ms. Morales is entitled to a reasonable understanding of when she may expect this matter to reach resolution, so that she may make informed decisions about her professional and personal circumstances. At a minimum, we request that C&H provide an estimated date by which it expects to deliver its final report to the Board, or, if that is not feasible, an estimated date by which it expects to be in a position to provide such an estimate.

IV. Reservation of Rights

Ms. Morales reserves all rights, claims, and remedies available to her under the California Fair Employment and Housing Act, California Government Code sections 12940 et seq., and under any other applicable federal, state, or local law. These reserved rights include, but are not limited to, the right to file a complaint with the California Civil Rights Department (formerly known as the Department of Fair Employment and Housing, or "DFEH") and/or to pursue civil litigation in a court of competent jurisdiction.

The demand letter dated April 20, 2023, issued by this firm to Aurelius Pacific Studios Inc., remains in full force and effect. Nothing in this letter, and nothing in Ms. Morales's ongoing cooperation with the investigation being conducted by Calderwood & Harkness LLP, shall be construed as a waiver, release, or limitation of any claims, rights, or remedies that Ms. Morales may have against Aurelius Pacific Studios Inc., Aurelius Global Media Group PLC, Marcus Hale, or any other individual or entity. Ms. Morales's cooperation with the investigation is voluntary and is undertaken in good faith; it does not constitute an election of remedies or an agreement to defer or forego any legal action.

We further note that the failure of Aurelius Pacific Studios Inc. and/or Aurelius Global Media Group PLC to provide the interim protective measures requested herein may be relevant to the question of whether the Company has complied with its obligations under California Government Code section 12940(k) to take all reasonable steps necessary to prevent harassment and retaliation. An employer's duty to prevent harassment and retaliation is affirmative and ongoing; it does not end with the initiation of an investigation, nor is it satisfied merely by placing an alleged harasser on administrative leave. The Company is obligated to take all reasonable steps to protect the complainant during and after the investigative process, and the failure to do so — particularly when specific, reasonable protective measures have been requested in writing — may constitute an independent basis for liability.

V. Request for Prompt Response

We respectfully request a written response to this letter within ten (10) business days of receipt, i.e., no later than July 21, 2023. We ask that the response address each of the five specific requests set forth in Section III above, and that it be accompanied by any written documentation evidencing the implementation of the requested protective measures.

If satisfactory assurances are not received within this timeframe, Ms. Morales will consider all available legal remedies, including but not limited to filing a complaint with the California Civil Rights Department and/or seeking injunctive relief from a court of competent jurisdiction to protect her employment status and ensure compliance with the Company's statutory obligations.

I am available to discuss this matter at your convenience. Please direct any response or questions to me at the contact information set forth above, or at my direct dial number, (213) 555-4118, or via email at sreeves@nakamurareeves.com.

Very truly yours,

NAKAMURA REEVES LLP

By: ________

Sandra Reeves Partner

cc: Jenna Morales (via email)

CONFIDENTIAL
NAKAMURA REEVES LLP Attorneys at Law
515 South Flower Street, Suite 3600 Los Angeles, California 90071 Telephone: (213) 555-4100 Facsimile: (213) 555-4101
Sandra Reeves, Partner Direct Dial: (213) 555-4118
Email: sreeves@nakamurareeves.com
July 7, 2023
VIA EMAIL AND U.S. MAIL
Bernard Crawford, Esq. Responsible Partner, Labor & Employment Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 2800 Los Angeles, California 90067
Re: Jenna Morales — Investigation into Allegations Against Marcus Hale, President, Aurelius Pacific Studios Inc. / Request for Interim Protective Measures
Dear Mr. Crawford:
I write on behalf of my client, Jenna Morales, Vice President of Development at Aurelius Pacific Studios Inc. ("APS" or the "Company"), in connection with the independent workplace investigation currently being conducted by your firm, Calderwood & Harkness LLP ("C&H"), at the direction of the Board of Directors of Aurelius Global Media Group PLC ("AGMG") into allegations of sexual harassment and retaliation against Marcus Hale, President of Aurelius Pacific Studios Inc.
As you are aware, your firm acknowledged by letter dated May 10, 2023, my firm's demand letter of April 20, 2023, and described the general scope and parameters of the investigation that C&H had been retained to conduct. Ms. Morales has cooperated fully with the investigation to date, including sitting for a comprehensive interview with your team on May 22, 2023, and she remains willing to continue her cooperation. This letter, however, addresses serious and growing concerns regarding the pace of the investigation and, more urgently, the need for immediate interim protective measures to safeguard Ms. Morales's employment status, professional standing, and well-being during and after the pendency of this matter.
I. Concerns Regarding the Pace of the Investigation
The investigation was formally opened on May 2, 2023 — now more than nine weeks ago. Ms. Morales's initial complaint, however, predates even that milestone. She filed her complaint via the Meridian Compliance Solutions Ethics & Compliance Hotline on April 18, 2023, and the matter was assigned case reference number MCS-2023-04871. That filing was made nearly eleven weeks ago as of the date of this letter.
Ms. Morales self-identified on April 19, 2023, at which time the complaint was escalated by Victor Gallegos, Vice President of Human Resources at Aurelius Pacific Studios Inc., to Fiona Blackwood, General Counsel of AGMG, and Patricia Sung, Chief People Officer of AGMG. Our firm sent its formal demand letter the following day, April 20, 2023, to Aurelius Pacific Studios Inc., setting forth detailed allegations of violations of the California Fair Employment and Housing Act, California Government Code sections 12940 et seq., and demanding both document preservation and appropriate remedial action. The demand letter was received and acknowledged by the Company's counsel.
Despite this timeline — and despite the seriousness of the underlying allegations — Ms. Morales has not been informed of any substantive findings, interim determinations, or anticipated timeline for the conclusion of the investigation. She has received no written or oral communication from C&H, from the Board, or from any representative of the Company regarding the status of the investigation since her interview on May 22, 2023. This silence, now extending for well over six weeks, is itself a source of significant professional and personal distress.
We acknowledge, of course, that C&H is conducting what we trust is a thorough and impartial investigation, and we do not suggest that corners should be cut in the service of expediency. Nevertheless, the passage of time without resolution — and, critically, without any interim communication regarding anticipated milestones — places Ms. Morales in a prolonged state of uncertainty and professional vulnerability. She is expected to continue performing at a high level in a workplace environment permeated by awareness of the investigation, while she herself has been afforded no assurance regarding her status or the outcome of the process she initiated.
California law imposes a clear obligation on employers to act with promptness. Under Government Code section 12940(k), employers are required to take immediate and appropriate corrective action in response to complaints of harassment and retaliation. The California Supreme Court has repeatedly emphasized that a "timely" investigation is a statutory requirement, not merely a best practice. See, e.g., Nazir v. Sterling Reach Holdings, Inc., 178 Cal. App. 4th 243, 288 (2009) (discussing the duty to investigate promptly and thoroughly). While we do not presently contend that the investigation has been unreasonably delayed such as to constitute a violation of these obligations, we wish to place on the record our concern that the current trajectory risks crossing that threshold if the matter continues without measurable progress or communication.
We further note that the seriousness of the allegations is underscored by the fact that Ms. Morales's complaint has been corroborated by at least two additional employees. Claire Ngo, Senior Director of Talent Relations at APS, filed her own complaint on April 24, 2023, describing separate incidents of harassment by Mr. Hale. Additionally, Darren Whitfield, Senior Vice President of Physical Production at APS, reported his own concerns regarding retaliatory conduct by Mr. Hale on April 26, 2023. The existence of multiple independent complaints involving the same alleged perpetrator — complaints that collectively describe a pattern of misconduct spanning multiple months and multiple settings — underscores the gravity of this matter and the urgency of its resolution.
II. Ms. Morales's Current Employment Situation and Ongoing Concerns
We are aware that Marcus Hale was placed on paid administrative leave on May 3, 2023, and that his access to company email, Meridian Solutions, and internal systems was suspended at that time. We appreciate that this step was taken promptly following the formal opening of the investigation, and we acknowledge it as an appropriate preliminary measure.
However, Mr. Hale's absence does not, by itself, resolve the concerns that Ms. Morales faces on a daily basis. She continues to work in an environment where the investigation remains unresolved and where awareness of its existence — and of her role as the complainant — has become increasingly widespread. Ms. Morales reports concerns that colleagues who are aware of the investigation may view her unfavorably, either as the individual responsible for the disruption caused by Mr. Hale's absence from his duties, or as a person whose professional judgment or motives may be questioned. She has observed what she perceives to be a cooling of professional relationships with certain colleagues who had previously been collaborative and supportive, and she is concerned that her career trajectory — including consideration for upcoming projects, promotion opportunities, and high-profile assignments — may be adversely affected as a consequence of having come forward.
These concerns are neither speculative nor trivial. The allegations in Ms. Morales's complaint describe a pattern of egregious conduct by Mr. Hale that warrants prompt protective action regardless of the investigation's final outcome. Specifically, the complaint details the following:
• Unwanted sexual advances by Mr. Hale directed at Ms. Morales from approximately September 2022 through March 2023, spanning a period of approximately seven months;
• Inappropriate conduct during the Vancouver production trip in October 2022, during which Mr. Hale made repeated personal and sexual overtures to Ms. Morales outside of professional settings, including at a private dinner on October 14, 2022, and at a hotel bar on October 15, 2022;
• Sexually suggestive text messages sent by Mr. Hale to Ms. Morales's personal mobile phone on November 14, 2022, November 29, 2022, and December 8, 2022, copies of which have been preserved and were provided to your firm during Ms. Morales's interview;
• Inappropriate comments made during a one-on-one meeting on January 11, 2023, in which Mr. Hale made remarks of a sexual nature regarding Ms. Morales's appearance and suggested that her career advancement would benefit from a closer personal relationship with him; and
• Unwanted physical contact at a company dinner on February 3, 2023, during which Mr. Hale placed his hand on Ms. Morales's lower back and upper thigh in the presence of colleagues, despite her visible discomfort and her prior express rejections of his advances.
Moreover, as detailed in her original complaint, Ms. Morales was subjected to retaliatory reassignment after she rejected Mr. Hale's advances. Specifically, she was removed from the high-profile "Meridian" development slate in March 2023 — a project to which she had been the lead development executive since its inception — and was reassigned to lower-priority projects without explanation or legitimate business justification. This reassignment occurred in the immediate aftermath of her most recent rejection of Mr. Hale's advances and, upon information and belief, at his direct instruction.
The foregoing allegations, taken together, describe precisely the type of serious, sustained, and retaliatory misconduct that California law requires employers to address with the utmost urgency and seriousness. The fact that the investigation remains pending does not relieve the Company or the Board of the obligation to take affirmative steps to protect Ms. Morales in the interim.
III. Specific Requests for Interim Protective Measures
In light of the foregoing, and in order to ensure that Ms. Morales's rights are adequately protected during the pendency of this investigation and beyond, we respectfully request that the following interim protective measures be implemented immediately:
A. Formal Written Anti-Retaliation Assurance. We request a formal written assurance, issued jointly by Aurelius Pacific Studios Inc. and Aurelius Global Media Group PLC, that Ms. Morales will not be subjected to any form of retaliation — including but not limited to adverse employment action, termination, constructive discharge, reassignment, demotion, reduction in responsibilities, exclusion from projects or meetings, negative performance evaluations, changes to her compensation or benefits, alteration of her reporting structure, social ostracism facilitated or tolerated by management, or any other action that could reasonably be perceived as retaliatory — as a consequence of having filed her complaint or cooperated with the investigation. This assurance should be memorialized in a written communication from an authorized representative of both entities and delivered to my office within the timeframe set forth in Section V below.
B. Preservation of Title, Responsibilities, Compensation, and Office Location. We request written confirmation that Ms. Morales's current title (Vice President of Development), reporting structure, job responsibilities, compensation (including base salary, bonus eligibility, and any other forms of remuneration), benefits, and office location will be preserved in their current form and will not be altered during the pendency of the investigation or in its aftermath without Ms. Morales's prior written consent. Any proposed changes to any aspect of Ms. Morales's employment terms should be communicated to this office in advance, together with a detailed statement of the business justification for such change, so that we may assess whether any such change is legitimate and non-retaliatory.
C. Designation of a Point of Contact for Ongoing Retaliation Concerns. We request that Aurelius Pacific Studios Inc. designate a specific individual — other than Victor Gallegos, Vice President of Human Resources, given his involvement as a witness in the investigation — to serve as a confidential point of contact to whom Ms. Morales may report any concerns about retaliation, hostile conduct, or other adverse treatment on an ongoing basis during and after the investigation. This individual should be sufficiently senior within the organization to take prompt remedial action if warranted and should have no personal involvement in the matters under investigation. We request that the identity and contact information of this designated individual be communicated to Ms. Morales and to this office in writing.
D. Reminder of Anti-Retaliation Policy to Relevant Personnel. We request that all senior leaders and employees who report to, interact regularly with, or supervise Ms. Morales be reminded, in writing, of the Company's anti-retaliation policy as set forth in the APS Employee Handbook, California Supplement, Section 5.7. This reminder should make clear that any retaliatory conduct directed at Ms. Morales — or at any other individual who has participated in or cooperated with the investigation — will be treated as a separate and independently actionable violation of Company policy warranting disciplinary action, up to and including termination. We request that a copy of this written reminder be provided to this office for our records.
E. Written Update on Investigation Timeline. We request a written update on the anticipated timeline for completion of the investigation and delivery of findings to the Board of Directors of AGMG. We understand that investigations of this nature require time and diligence, and we are not requesting that C&H disclose the substance of its findings or compromise the integrity of its process. However, Ms. Morales is entitled to a reasonable understanding of when she may expect this matter to reach resolution, so that she may make informed decisions about her professional and personal circumstances. At a minimum, we request that C&H provide an estimated date by which it expects to deliver its final report to the Board, or, if that is not feasible, an estimated date by which it expects to be in a position to provide such an estimate.
IV. Reservation of Rights
Ms. Morales reserves all rights, claims, and remedies available to her under the California Fair Employment and Housing Act, California Government Code sections 12940 et seq., and under any other applicable federal, state, or local law. These reserved rights include, but are not limited to, the right to file a complaint with the California Civil Rights Department (formerly known as the Department of Fair Employment and Housing, or "DFEH") and/or to pursue civil litigation in a court of competent jurisdiction.
The demand letter dated April 20, 2023, issued by this firm to Aurelius Pacific Studios Inc., remains in full force and effect. Nothing in this letter, and nothing in Ms. Morales's ongoing cooperation with the investigation being conducted by Calderwood & Harkness LLP, shall be construed as a waiver, release, or limitation of any claims, rights, or remedies that Ms. Morales may have against Aurelius Pacific Studios Inc., Aurelius Global Media Group PLC, Marcus Hale, or any other individual or entity. Ms. Morales's cooperation with the investigation is voluntary and is undertaken in good faith; it does not constitute an election of remedies or an agreement to defer or forego any legal action.
We further note that the failure of Aurelius Pacific Studios Inc. and/or Aurelius Global Media Group PLC to provide the interim protective measures requested herein may be relevant to the question of whether the Company has complied with its obligations under California Government Code section 12940(k) to take all reasonable steps necessary to prevent harassment and retaliation. An employer's duty to prevent harassment and retaliation is affirmative and ongoing; it does not end with the initiation of an investigation, nor is it satisfied merely by placing an alleged harasser on administrative leave. The Company is obligated to take all reasonable steps to protect the complainant during and after the investigative process, and the failure to do so — particularly when specific, reasonable protective measures have been requested in writing — may constitute an independent basis for liability.
V. Request for Prompt Response
We respectfully request a written response to this letter within ten (10) business days of receipt, i.e., no later than July 21, 2023. We ask that the response address each of the five specific requests set forth in Section III above, and that it be accompanied by any written documentation evidencing the implementation of the requested protective measures.
If satisfactory assurances are not received within this timeframe, Ms. Morales will consider all available legal remedies, including but not limited to filing a complaint with the California Civil Rights Department and/or seeking injunctive relief from a court of competent jurisdiction to protect her employment status and ensure compliance with the Company's statutory obligations.
I am available to discuss this matter at your convenience. Please direct any response or questions to me at the contact information set forth above, or at my direct dial number, (213) 555-4118, or via email at sreeves@nakamurareeves.com.
Very truly yours,
NAKAMURA REEVES LLP
By: ________
Sandra Reeves Partner
cc: Jenna Morales (via email)

CONFIDENTIAL

VIA EMAIL AND U.S. MAIL

NAKAMURA REEVES LLP

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