1017-00005 · Aurelius Global Media Group · Engagement

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PRIVILEGED AND CONFIDENTIAL — PREPARED AT THE DIRECTION OF COUNSEL

DOCUMENT PRESERVATION / LITIGATION HOLD NOTICE

AURELIUS PACIFIC STUDIOS INC.

May 2, 2023

FROM: Victor Gallegos Vice President of Human Resources Aurelius Pacific Studios Inc. 3200 West Alameda Avenue, Suite 400 Burbank, CA 91505

DRAFTED BY / AT THE DIRECTION OF: Calderwood & Harkness LLP Outside Counsel to Aurelius Global Media Group PLC 1999 Avenue of the Stars, Suite 2800 Los Angeles, CA 90067 Matter No. 1017-00005

TO: All custodians identified in Section IV below, and any additional custodians as may be subsequently identified

RE: Preservation of Documents and Electronically Stored Information Relating to Allegations Involving Marcus Hale, President of Aurelius Pacific Studios Inc.

I. Purpose and Legal Obligation

Aurelius Pacific Studios Inc. ("APS" or the "Company"), a wholly owned subsidiary of Aurelius Global Media Group PLC ("AGMG"), has a legal duty to preserve all documents and electronically stored information ("ESI") that may be relevant to pending or reasonably anticipated claims, investigations, or litigation. This duty arises under both federal and California state law, including the common law duty to preserve evidence, and is triggered when litigation or a government investigation is pending or reasonably anticipated. The Company takes this obligation with the utmost seriousness and expects full and immediate compliance from every recipient of this notice.

The Board of Directors of AGMG, through its People & Culture Committee (chaired by Dame Cordelia Ashworth) and its Audit & Risk Committee (chaired by Raymond Okoro), has authorized Calderwood & Harkness LLP to conduct an independent privileged workplace investigation into allegations of sexual harassment, retaliation, and hostile work environment involving Marcus Hale, President of APS. This investigation has been initiated in the exercise of the Board's oversight responsibilities and in furtherance of the Company's commitment to maintaining a workplace free from harassment, discrimination, and retaliation.

This litigation hold is issued in connection with that investigation, as well as in connection with potential claims asserted by or on behalf of Jenna Morales, Vice President of Development at APS. On April 20, 2023, the Company received a formal demand letter from Nakamura Reeves LLP, counsel for Ms. Morales, alleging violations of the California Fair Employment and Housing Act, California Government Code sections 12940 et seq., including but not limited to claims of sexual harassment, quid pro quo harassment, retaliation for engaging in protected activity, and failure to prevent harassment and discrimination. The demand letter further indicated Ms. Morales's intention to file a complaint with the California Civil Rights Department (formerly the Department of Fair Employment and Housing) and to pursue civil litigation if the matter is not resolved.

In addition to the claims asserted by Ms. Morales, the Company has received complaints from Claire Ngo, Senior Director of Talent Relations at APS, and Darren Whitfield, Senior Vice President of Physical Production at APS, each of whom has raised concerns regarding the conduct of Marcus Hale. These complaints are being evaluated as part of the Calderwood & Harkness LLP investigation and may give rise to additional claims, investigations, or proceedings.

Given the nature and seriousness of these allegations, the Company has determined that litigation is reasonably anticipated, and this litigation hold is being issued to ensure that all potentially relevant documents and ESI are identified and preserved. This notice supersedes any routine document retention or destruction policies currently in effect at APS or AGMG, including but not limited to the AGMG Records Retention and Information Governance Policy (effective September 1, 2021). All automated deletion programs, including email auto-purge schedules, scheduled tape rotation or overwrite cycles, and any other automated processes that could result in the destruction or alteration of potentially relevant materials, must be suspended immediately for the categories of materials described herein.

Failure to comply with this notice may result in the spoliation of evidence, which can lead to severe adverse legal consequences for the Company, including but not limited to court-imposed sanctions, adverse inference instructions, monetary penalties, and other remedial measures. In addition, any individual who fails to preserve relevant materials in accordance with this notice may be subject to disciplinary action, up to and including termination of employment, as well as potential personal liability.

II. Effective Date and Preservation Period

This litigation hold is effective immediately as of May 2, 2023. All recipients of this notice are required to take immediate action to identify and preserve all documents and ESI within the scope of this hold, as described in Section III below, and to cease any destruction, deletion, alteration, or modification of such materials.

The temporal scope of materials to be preserved encompasses all documents and ESI created, sent, received, modified, or stored during the period from January 1, 2019 to the present (the "Preservation Period"). The Preservation Period begins on the approximate date on which Marcus Hale commenced his role as President of Aurelius Pacific Studios Inc. and encompasses his entire tenure in that position through the date of this notice and continuing forward. All materials within this date range that fall within the subject matter categories described in Section III must be preserved, regardless of their perceived significance or relevance. Determinations of relevance will be made by counsel; custodians and other employees are not authorized to make independent judgments regarding whether particular materials are or are not within the scope of this hold.

This litigation hold will remain in effect until it is formally released in writing by Victor Gallegos, Vice President of Human Resources, upon written authorization from Calderwood & Harkness LLP. Recipients must not destroy, delete, discard, overwrite, or alter any covered materials until such a written release has been received. No oral communication, informal email, or other informal notification shall constitute a valid release of this hold. Until a formal written release is issued, all preservation obligations described in this notice remain in full force and effect.

No documents within the scope of this hold may be destroyed, discarded, deleted, overwritten, modified, or altered in any way, regardless of the Company's ordinary retention schedules, departmental practices, or individual document management habits. This prohibition applies to all formats and media, including paper documents, electronic files, emails, text messages, instant messages, voicemail, backup media, and any other form in which potentially relevant information may be stored.

III. Scope of Materials to Be Preserved

A. Subject Matter

All documents, communications, and ESI relating to, referencing, or concerning any of the following subject matter areas must be preserved. This list is intended to be comprehensive but not exhaustive; if you have questions about whether particular materials fall within the scope of this hold, you should err on the side of preservation and contact Victor Gallegos or Calderwood & Harkness LLP immediately for guidance.

1. Marcus Hale (President, APS) — including, without limitation, his conduct, management decisions, management style, interactions with employees (whether professional or personal in nature), travel and entertainment activities, expense reports, use of Company resources, and any communications to, from, or concerning Hale in any context relevant to the subject matter of this hold.

2. Jenna Morales (Vice President of Development, APS) — including, without limitation, her employment history at APS, work assignments, project responsibilities, complaints (whether formal or informal) made by or regarding her, interactions with Marcus Hale, performance evaluations, compensation history, any changes to her role, responsibilities, or reporting structure, and any communications to, from, or concerning Morales relevant to the subject matter of this hold.

3. Claire Ngo (Senior Director of Talent Relations, APS) — including, without limitation, her employment history at APS, complaints (whether formal or informal) made by or regarding her, any instances of exclusion from meetings, events, or decision-making processes, interactions with Marcus Hale, performance evaluations, compensation history, and any communications to, from, or concerning Ngo relevant to the subject matter of this hold.

4. Darren Whitfield (SVP of Physical Production, APS) — including, without limitation, his employment history at APS, work assignments, project responsibilities, any concerns raised by Whitfield about Hale's conduct, the reassignment of production projects from Whitfield to other personnel (including but not limited to projects known internally as "Project Meridian" and "Project Halcyon"), performance evaluations, compensation history, and any communications to, from, or concerning Whitfield relevant to the subject matter of this hold.

5. Cameron Briggs (SVP of Production, APS) — including, without limitation, the reassignment of Project Meridian and Project Halcyon to Briggs from Whitfield, Briggs's communications with Hale regarding such reassignments, any communications to, from, or concerning Briggs relevant to the subject matter of this hold, and any documents relating to the decision-making process surrounding those project reassignments.

6. Serena Whitcomb (former Executive Assistant to Marcus Hale, employed approximately April 2019 through September 2021) — including, without limitation, any prior complaints made by or regarding Whitcomb, interactions between Whitcomb and the Human Resources department, the circumstances of her separation from the Company, any exit interview documentation, any severance or separation agreements, and any communications to, from, or concerning Whitcomb relevant to the subject matter of this hold.

7. Any allegations, complaints, reports, or concerns regarding sexual harassment, inappropriate conduct, hostile work environment, discrimination, or retaliation involving any APS employee, whether made formally through the Company's complaint procedures, informally to a manager or Human Resources representative, or through any other channel, including the AGMG Ethics & Compliance Hotline.

8. The Ethics & Compliance Hotline complaint filed on April 18, 2023 (Meridian Compliance Solutions LLC case reference MCS-1014-00001), including the original complaint, any intake notes, investigative memoranda, communications with the reporter, follow-up actions taken, and any related hotline reports filed before or after this date that concern the same or similar subject matter.

9. Any HR investigations, counseling, warnings, or disciplinary actions involving Marcus Hale, including without limitation the verbal counseling issued to Hale on or about August 2, 2021, any documentation of that counseling session, any follow-up actions or monitoring undertaken in connection therewith, and any other formal or informal disciplinary measures, performance improvement plans, or counseling sessions involving Hale during the Preservation Period.

10. Company off-site events, retreats, dinners, and production travel, including but not limited to the following:

• The off-site event held on February 17–18, 2023 at the Monarch Valley Resort, Ojai, California, including all planning documents, attendee lists, expense reports, photographs, communications regarding the event, and any incident reports or complaints arising from the event;

• The production trip to Vancouver, British Columbia in or around October 2022, including travel itineraries, attendee lists, expense reports, and any communications or complaints arising from or relating to that trip;

• The company dinner held on or about February 3, 2023, including planning documents, attendee lists, expense reports, and any communications or complaints arising from or relating to that dinner; and

• Any other off-site events, retreats, dinners, or production travel during the Preservation Period at which Hale was present and which may be relevant to the allegations described herein.

11. Performance reviews, personnel files, and employment records for Marcus Hale, Jenna Morales, Claire Ngo, Darren Whitfield, Cameron Briggs, and Serena Whitcomb, including all documents maintained in the Company's HRIS (Human Resources Information System), physical personnel files, and any records maintained by individual managers.

12. All policies, handbooks, and training materials relating to anti-harassment, anti-discrimination, anti-retaliation, and complaint procedures, including but not limited to:

• The AGMG Global Code of Conduct, Version 4.2, effective January 1, 2022, and all prior versions in effect during the Preservation Period;

• The APS Employee Handbook, California Supplement, revised March 15, 2022, in particular Sections 5.3 (Anti-Harassment Policy), 5.7 (Complaint Procedures), and 8.1 (Anti-Retaliation Policy), and all prior versions in effect during the Preservation Period;

• The AGMG Board Corporate Governance Guidelines, Section 12 (Executive Conduct and Oversight), and all prior versions in effect during the Preservation Period;

• All training materials, attendance records, and certifications relating to harassment prevention training required under California Government Code section 12950.1 and related regulations; and

• Any other Company policies, procedures, or guidelines relating to workplace conduct, ethics, or compliance that may be relevant to the subject matter of this hold.

B. Types of Documents and ESI

The following categories describe the types of documents and ESI that must be preserved. This list is illustrative and is intended to encompass all formats and media in which potentially relevant information may exist:

• Email communications: All emails (including sent, received, drafts, deleted items/trash folder, archived items, and items in any sub-folders) on the Company's email system (currently Outlook / Exchange), including all attachments. This encompasses both internal and external email communications.

• Instant messaging and collaboration platforms: All messages on Meridian Solutions (including direct messages, group channels, and private channels), Northgate Data Systems, or any other messaging or collaboration platform used by APS or its employees for business purposes. This includes any messages that have been archived, muted, or moved to inactive channels.

• Text messages and mobile communications: All SMS, MMS, Westmark Software, Meridian Services Inc., Harborline Technologies, Kestrel Data Systems, or other messaging application communications on Company-issued devices or personal devices used for Company business. Custodians who have used personal devices for business-related communications are required to preserve all such communications.

• Calendar entries: All calendar items, meeting invitations, meeting acceptances and declines, scheduling records, and associated notes or attachments, whether maintained in Outlook, Brightmoor Services Inc., or any other calendaring application.

• Documents and files: All word processing documents, spreadsheets, presentations, PDFs, memoranda, reports, notes, and other files, whether stored on local hard drives, network shared drives (including the APS shared drive and any departmental drives), cloud storage services (including Severin Services Inc., Aldermere Systems, Hollowell Health IT, Larkspur Technologies, or any other cloud storage platform), or personal devices used for Company business.

• Human resources records: Personnel files, performance evaluations, compensation records, bonus and incentive plan records, disciplinary records, counseling records, complaint files, investigation files, hotline logs, intake forms, exit interview notes, separation and release agreements, and any other HR documentation relevant to the subject matter described above.

• Voicemail: All voicemail messages, whether stored on Company phone systems (including desk phones, voicemail servers, and unified messaging systems) or personal devices used for Company business.

• Social media: Any business-related communications conducted through social media platforms, including but not limited to Westmark Health IT, Northpoint Services Inc., Ashford Systems, Kestrel Services Inc., and any other social media services, to the extent such communications relate to the subject matter of this hold.

• Physical/hard-copy documents: All paper files, handwritten notes, printed documents, physical correspondence, photographs, and any other tangible records relevant to the subject matter described above, wherever such materials are located, including in office files, desk drawers, filing cabinets, home offices, or any other location.

• Metadata: All metadata associated with the above categories of ESI must be preserved in its native format. Documents must not be printed to paper, converted to PDF, or otherwise altered or converted in a manner that would strip, modify, or destroy metadata. Metadata includes but is not limited to file creation dates, modification dates, author information, recipient information, file paths, and tracked changes or revision history.

• Backup tapes and systems: The IT department must ensure that any backup tapes, disaster-recovery archives, system snapshots, or other backup media containing materials within the scope of this hold are preserved and not overwritten, recycled, or destroyed. This includes both on-premises backup systems and cloud-based backup or archival services.

IV. Custodians

The following individuals are identified as custodians whose documents and ESI must be preserved pursuant to this litigation hold. Additional custodians may be identified and notified as the investigation proceeds, in coordination between Victor Gallegos and Calderwood & Harkness LLP. Each custodian listed below will receive a copy of this notice and is required to comply with all obligations described herein.

1. Marcus Hale — President, Aurelius Pacific Studios Inc. Mr. Hale has been placed on paid administrative leave effective May 3, 2023. His system access, including email, Meridian Solutions, VPN, and all Company network access, has been suspended as of that date. The IT department is directed to preserve all data associated with Mr. Hale's accounts and devices in place, in their current state, and to ensure that no data is deleted, overwritten, or modified. Mr. Hale's Company-issued devices (including laptop, mobile phone, and any other equipment) must be collected and secured by the IT department in coordination with Calderwood & Harkness LLP.

2. Jenna Morales — Vice President of Development, Aurelius Pacific Studios Inc.

3. Claire Ngo — Senior Director of Talent Relations, Aurelius Pacific Studios Inc.

4. Darren Whitfield — Senior Vice President of Physical Production, Aurelius Pacific Studios Inc.

5. Cameron Briggs — Senior Vice President of Production, Aurelius Pacific Studios Inc.

6. Victor Gallegos — Vice President of Human Resources, Aurelius Pacific Studios Inc.

7. Additional SVP-level direct reports of Marcus Hale, to be identified in coordination with Calderwood & Harkness LLP. Once identified, these individuals will be provided with a copy of this notice and will be subject to the same preservation obligations.

8. Any current or former employee who may be identified as a relevant witness during the course of the investigation. Such individuals will be notified and provided with a copy of this notice as they are identified.

Note Regarding Former Employees: With respect to Serena Whitcomb (former Executive Assistant to Marcus Hale, employed approximately April 2019 through September 2021) and any other former employees who may be relevant to this matter, all Company records, files, and ESI relating to those individuals that remain in the custody, possession, or control of the Company must be preserved. This includes, without limitation, personnel files, email archives, separation agreements, exit interview documentation, and any other records retained by the Company following the individual's separation. The Company does not have authority to direct former employees to preserve their personal records, but any Company records relating to former employees must be preserved in full.

V. Obligations of Custodians

Each custodian identified in Section IV above is personally responsible for ensuring the preservation of all materials within their custody, possession, or control that fall within the scope of this hold. The preservation obligation extends to all locations and devices where relevant materials may be stored, including Company systems, Company-issued devices, personal devices used for business purposes, home offices, personal email accounts used for business purposes, personal cloud storage accounts, and any other location where relevant materials may exist.

Specifically, each custodian must:

1. Immediately cease any destruction, deletion, or alteration of potentially relevant materials. This includes ceasing any manual deletion of emails, text messages, instant messages, voicemails, files, or any other documents or ESI that may fall within the scope of this hold. Do not "clean up," reorganize, or otherwise alter any files, folders, or communications.

2. Search for and identify all physical and electronic locations where relevant materials may be stored. This includes, without limitation:

• Company-issued laptops, desktops, and other computing devices;

• Company-issued mobile phones and tablets;

• Personal devices (phones, laptops, tablets) used for Company business;

• Home offices, including any paper files, notes, or documents stored at your residence;

• Personal email accounts (e.g., Northgate Software, Cascade Health IT, Ridgeline Technologies) used for any business-related communications;

• Personal cloud storage accounts (e.g., Hollowell Health IT, Larkspur Technologies, Meridian Systems) where business-related documents may be stored;

• USB drives, external hard drives, or other portable storage media; and

• Any other location where potentially relevant materials may exist.

3. Disable any auto-delete functions on email accounts, messaging applications (including Meridian Solutions, Meridian Services Inc., Harborline Technologies, and any other applications with message expiration or auto-delete features), and mobile devices. If you are unsure how to disable auto-delete functions, contact the IT department or Victor Gallegos immediately for assistance.

4. Preserve all relevant materials in their current location and format. Do not move, copy to a new format, reorganize, rename, or otherwise alter materials unless specifically directed to do so by Calderwood & Harkness LLP or Victor Gallegos. The goal is to maintain materials in their existing state to preserve their integrity, including all associated metadata.

5. Promptly notify Victor Gallegos if any relevant materials have already been deleted, destroyed, or are at risk of loss. If you are aware of any materials that were destroyed or deleted before or after the date of this notice that may fall within the scope of this hold, you must report this immediately. Similarly, if you become aware of any materials that are at risk of loss or destruction (for example, due to device malfunction, storage limitations, or any other reason), you must report this without delay so that appropriate steps can be taken to preserve such materials.

6. Do not discuss the substance of this litigation hold or the underlying investigation with other employees, other than as directed by Calderwood & Harkness LLP or Victor Gallegos. The integrity of the investigation depends on maintaining confidentiality. You should not discuss the contents of this notice, the fact that you received it, or any aspect of the underlying allegations with colleagues, subordinates, or any other individuals, except as necessary to comply with the instructions set forth herein or as directed by counsel. If you are approached by another employee with questions about the investigation or this hold, direct them to Victor Gallegos.

If at any time during the pendency of this litigation hold you become aware of additional materials that may fall within the scope of this hold, or if you have any doubt about whether particular materials should be preserved, you must err on the side of preservation and contact Victor Gallegos or Calderwood & Harkness LLP for guidance.

VI. IT Department Obligations

The APS Information Technology department, under the supervision of the Chief Information Officer or the most senior IT leader within APS, is directed to take the following actions immediately and to continue these measures for the duration of this litigation hold:

1. Suspend all auto-delete, auto-archive, or recycling routines for email (Outlook / Exchange), Meridian Solutions, Northgate Data Systems, and any other messaging or collaboration platforms in use at APS, for all custodians identified in Section IV above. This includes any Company-wide or departmental auto-purge schedules, mailbox size limitations that trigger automatic deletion, and any retention policies that would result in the automated destruction of data within the scope of this hold.

2. Preserve backup tapes and system images that may contain data within the Preservation Period (January 1, 2019 to the present). No backup tapes, disaster-recovery media, or system snapshots that contain or may contain data within the scope of this hold shall be overwritten, recycled, degaussed, or destroyed. The IT department shall maintain a current inventory of all backup media subject to this preservation directive.

3. Preserve the APS Meridian Solutions workspace data, including all channels (both public and private) and all direct messages for identified custodians. If Meridian Solutions data is subject to any data retention limits or automatic deletion policies, these must be suspended immediately. The IT department shall coordinate with Calderwood & Harkness LLP regarding the export and preservation of Meridian Solutions data as needed.

4. Ensure that the email account and all system access credentials for Marcus Hale (currently suspended due to his administrative leave status) remain preserved and accessible for forensic collection. Mr. Hale's email account, Meridian Solutions account, network home directory, Cobalt Ridge Systems or Aldermere Systems data, and any other data repositories associated with his accounts must not be deleted, purged, or modified in any way. All Company-issued devices assigned to Mr. Hale must be collected, secured, and stored in a manner that preserves their forensic integrity.

5. Cooperate with Linden Forensics Group Inc. (201 Mission Street, Suite 1400, San Francisco, CA 94105), the digital forensics firm retained by Calderwood & Harkness LLP, in connection with any forensic data collection, imaging, or analysis efforts. The IT department shall provide Linden Forensics Group with such access to Company systems, devices, and data as may be reasonably necessary to carry out forensic preservation and collection activities, subject to coordination with Calderwood & Harkness LLP.

6. Maintain chain-of-custody documentation for any data preserved, collected, or produced pursuant to this hold. All transfers of data, devices, or media must be documented with the date, time, individuals involved, description of materials, and purpose of the transfer. Chain-of-custody logs shall be maintained in a secure location and made available to Calderwood & Harkness LLP upon request.

7. Do not alter, modify, or reset any passwords or security settings for custodian accounts without prior written authorization from Victor Gallegos. Any changes to access controls, authentication credentials, or security configurations for custodian accounts could compromise the integrity of preserved data and must be coordinated with counsel.

The IT department should designate a single point of contact for all matters relating to this litigation hold and provide that individual's name and contact information to Victor Gallegos and Calderwood & Harkness LLP within two (2) business days of receipt of this notice.

VII. Consequences of Non-Compliance

The obligation to preserve relevant evidence when litigation or an investigation is pending or reasonably anticipated is a serious legal duty imposed by law. All recipients of this notice are expected to comply fully and promptly with every requirement set forth herein.

Failure to comply with this litigation hold may have severe consequences, including but not limited to the following:

• Adverse legal consequences for the Company: Spoliation of evidence — the destruction, alteration, or failure to preserve potentially relevant materials — may expose Aurelius Pacific Studios Inc. and Aurelius Global Media Group PLC to court-imposed sanctions, including adverse inference instructions (which permit a judge or jury to presume that destroyed evidence was unfavorable to the Company), monetary sanctions, issue preclusion, or, in extreme cases, default judgment or dismissal of claims. Spoliation may also give rise to independent tort claims and regulatory penalties.

• Disciplinary action against individuals: Any individual who intentionally or negligently destroys, conceals, alters, or fails to preserve documents or ESI within the scope of this hold will be subject to disciplinary action, up to and including termination of employment. The Company will not tolerate any interference with its preservation obligations or the integrity of the ongoing investigation.

If you have any questions regarding the scope of this hold, whether particular documents or ESI fall within its scope, or how to comply with any aspect of this notice, you must direct those questions immediately to:

• Victor Gallegos, Vice President of Human Resources, Aurelius Pacific Studios Inc., 3200 West Alameda Avenue, Suite 400, Burbank, CA 91505; or

• Devon Archer, Calderwood & Harkness LLP, 1999 Avenue of the Stars, Suite 2800, Los Angeles, CA 90067.

Do not attempt to resolve questions of scope or compliance on your own. When in doubt, preserve the materials in question and seek guidance from the contacts listed above.

VIII. Acknowledgment and Confirmation

Each recipient of this notice is required to confirm receipt and understanding of this Litigation Hold Notice by completing, signing, and returning the acknowledgment form below to Victor Gallegos, Vice President of Human Resources, within three (3) business days of receipt. The signed acknowledgment form may be delivered in person, by interoffice mail, or by email (scanned copy) to Victor Gallegos at the address set forth below.

Failure to return the signed acknowledgment within the required timeframe will be treated as a compliance concern and will be reported to Calderwood & Harkness LLP.

ACKNOWLEDGMENT OF RECEIPT — LITIGATION HOLD NOTICE

Aurelius Pacific Studios Inc.

Dated: May 2, 2023

I acknowledge receipt of this Litigation Hold Notice dated May 2, 2023. I understand my obligation to preserve all documents and electronically stored information described herein and will comply with its terms. I confirm that I have not destroyed, deleted, or altered any potentially relevant materials after the date of this notice. I further understand that I must comply with all requirements set forth in this notice and that failure to do so may result in disciplinary action, up to and including termination of employment, as well as adverse legal consequences for the Company.

Printed Name: ____________

Title / Position: ____________

Date of Receipt: ____________

Signature: ________

IX. Contact Information for Questions

All questions regarding the scope of materials to be preserved, how to handle specific documents or categories of ESI, technical issues with preservation (such as disabling auto-delete functions or preserving data on personal devices), or any other aspect of this litigation hold should be directed to one of the following contacts without delay:

Victor Gallegos Vice President of Human Resources Aurelius Pacific Studios Inc. 3200 West Alameda Avenue, Suite 400 Burbank, CA 91505

Devon Archer Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 2800 Los Angeles, CA 90067

When in doubt about whether a particular document, communication, or category of information falls within the scope of this hold, err on the side of preservation and contact one of the individuals listed above for guidance. Prompt communication is essential to ensure that the Company meets its legal obligations and that the integrity of the investigation is maintained.

PRIVILEGED AND CONFIDENTIAL — PREPARED AT THE DIRECTION OF COUNSEL — CALDERWOOD & HARKNESS LLP

Calderwood & Harkness LLP — Matter No. 1017-00005

PRIVILEGED AND CONFIDENTIAL — PREPARED AT THE DIRECTION OF COUNSEL
DOCUMENT PRESERVATION / LITIGATION HOLD NOTICE
AURELIUS PACIFIC STUDIOS INC.
May 2, 2023
FROM: Victor Gallegos Vice President of Human Resources Aurelius Pacific Studios Inc. 3200 West Alameda Avenue, Suite 400 Burbank, CA 91505
DRAFTED BY / AT THE DIRECTION OF: Calderwood & Harkness LLP Outside Counsel to Aurelius Global Media Group PLC 1999 Avenue of the Stars, Suite 2800 Los Angeles, CA 90067 Matter No. 1017-00005
TO: All custodians identified in Section IV below, and any additional custodians as may be subsequently identified
RE: Preservation of Documents and Electronically Stored Information Relating to Allegations Involving Marcus Hale, President of Aurelius Pacific Studios Inc.
I. Purpose and Legal Obligation
Aurelius Pacific Studios Inc. ("APS" or the "Company"), a wholly owned subsidiary of Aurelius Global Media Group PLC ("AGMG"), has a legal duty to preserve all documents and electronically stored information ("ESI") that may be relevant to pending or reasonably anticipated claims, investigations, or litigation. This duty arises under both federal and California state law, including the common law duty to preserve evidence, and is triggered when litigation or a government investigation is pending or reasonably anticipated. The Company takes this obligation with the utmost seriousness and expects full and immediate compliance from every recipient of this notice.
The Board of Directors of AGMG, through its People & Culture Committee (chaired by Dame Cordelia Ashworth) and its Audit & Risk Committee (chaired by Raymond Okoro), has authorized Calderwood & Harkness LLP to conduct an independent privileged workplace investigation into allegations of sexual harassment, retaliation, and hostile work environment involving Marcus Hale, President of APS. This investigation has been initiated in the exercise of the Board's oversight responsibilities and in furtherance of the Company's commitment to maintaining a workplace free from harassment, discrimination, and retaliation.
This litigation hold is issued in connection with that investigation, as well as in connection with potential claims asserted by or on behalf of Jenna Morales, Vice President of Development at APS. On April 20, 2023, the Company received a formal demand letter from Nakamura Reeves LLP, counsel for Ms. Morales, alleging violations of the California Fair Employment and Housing Act, California Government Code sections 12940 et seq., including but not limited to claims of sexual harassment, quid pro quo harassment, retaliation for engaging in protected activity, and failure to prevent harassment and discrimination. The demand letter further indicated Ms. Morales's intention to file a complaint with the California Civil Rights Department (formerly the Department of Fair Employment and Housing) and to pursue civil litigation if the matter is not resolved.
In addition to the claims asserted by Ms. Morales, the Company has received complaints from Claire Ngo, Senior Director of Talent Relations at APS, and Darren Whitfield, Senior Vice President of Physical Production at APS, each of whom has raised concerns regarding the conduct of Marcus Hale. These complaints are being evaluated as part of the Calderwood & Harkness LLP investigation and may give rise to additional claims, investigations, or proceedings.
Given the nature and seriousness of these allegations, the Company has determined that litigation is reasonably anticipated, and this litigation hold is being issued to ensure that all potentially relevant documents and ESI are identified and preserved. This notice supersedes any routine document retention or destruction policies currently in effect at APS or AGMG, including but not limited to the AGMG Records Retention and Information Governance Policy (effective September 1, 2021). All automated deletion programs, including email auto-purge schedules, scheduled tape rotation or overwrite cycles, and any other automated processes that could result in the destruction or alteration of potentially relevant materials, must be suspended immediately for the categories of materials described herein.
Failure to comply with this notice may result in the spoliation of evidence, which can lead to severe adverse legal consequences for the Company, including but not limited to court-imposed sanctions, adverse inference instructions, monetary penalties, and other remedial measures. In addition, any individual who fails to preserve relevant materials in accordance with this notice may be subject to disciplinary action, up to and including termination of employment, as well as potential personal liability.
II. Effective Date and Preservation Period
This litigation hold is effective immediately as of May 2, 2023. All recipients of this notice are required to take immediate action to identify and preserve all documents and ESI within the scope of this hold, as described in Section III below, and to cease any destruction, deletion, alteration, or modification of such materials.
The temporal scope of materials to be preserved encompasses all documents and ESI created, sent, received, modified, or stored during the period from January 1, 2019 to the present (the "Preservation Period"). The Preservation Period begins on the approximate date on which Marcus Hale commenced his role as President of Aurelius Pacific Studios Inc. and encompasses his entire tenure in that position through the date of this notice and continuing forward. All materials within this date range that fall within the subject matter categories described in Section III must be preserved, regardless of their perceived significance or relevance. Determinations of relevance will be made by counsel; custodians and other employees are not authorized to make independent judgments regarding whether particular materials are or are not within the scope of this hold.
This litigation hold will remain in effect until it is formally released in writing by Victor Gallegos, Vice President of Human Resources, upon written authorization from Calderwood & Harkness LLP. Recipients must not destroy, delete, discard, overwrite, or alter any covered materials until such a written release has been received. No oral communication, informal email, or other informal notification shall constitute a valid release of this hold. Until a formal written release is issued, all preservation obligations described in this notice remain in full force and effect.
No documents within the scope of this hold may be destroyed, discarded, deleted, overwritten, modified, or altered in any way, regardless of the Company's ordinary retention schedules, departmental practices, or individual document management habits. This prohibition applies to all formats and media, including paper documents, electronic files, emails, text messages, instant messages, voicemail, backup media, and any other form in which potentially relevant information may be stored.
III. Scope of Materials to Be Preserved
A. Subject Matter
All documents, communications, and ESI relating to, referencing, or concerning any of the following subject matter areas must be preserved. This list is intended to be comprehensive but not exhaustive; if you have questions about whether particular materials fall within the scope of this hold, you should err on the side of preservation and contact Victor Gallegos or Calderwood & Harkness LLP immediately for guidance.
1. Marcus Hale (President, APS) — including, without limitation, his conduct, management decisions, management style, interactions with employees (whether professional or personal in nature), travel and entertainment activities, expense reports, use of Company resources, and any communications to, from, or concerning Hale in any context relevant to the subject matter of this hold.
2. Jenna Morales (Vice President of Development, APS) — including, without limitation, her employment history at APS, work assignments, project responsibilities, complaints (whether formal or informal) made by or regarding her, interactions with Marcus Hale, performance evaluations, compensation history, any changes to her role, responsibilities, or reporting structure, and any communications to, from, or concerning Morales relevant to the subject matter of this hold.
3. Claire Ngo (Senior Director of Talent Relations, APS) — including, without limitation, her employment history at APS, complaints (whether formal or informal) made by or regarding her, any instances of exclusion from meetings, events, or decision-making processes, interactions with Marcus Hale, performance evaluations, compensation history, and any communications to, from, or concerning Ngo relevant to the subject matter of this hold.
4. Darren Whitfield (SVP of Physical Production, APS) — including, without limitation, his employment history at APS, work assignments, project responsibilities, any concerns raised by Whitfield about Hale's conduct, the reassignment of production projects from Whitfield to other personnel (including but not limited to projects known internally as "Project Meridian" and "Project Halcyon"), performance evaluations, compensation history, and any communications to, from, or concerning Whitfield relevant to the subject matter of this hold.
5. Cameron Briggs (SVP of Production, APS) — including, without limitation, the reassignment of Project Meridian and Project Halcyon to Briggs from Whitfield, Briggs's communications with Hale regarding such reassignments, any communications to, from, or concerning Briggs relevant to the subject matter of this hold, and any documents relating to the decision-making process surrounding those project reassignments.
6. Serena Whitcomb (former Executive Assistant to Marcus Hale, employed approximately April 2019 through September 2021) — including, without limitation, any prior complaints made by or regarding Whitcomb, interactions between Whitcomb and the Human Resources department, the circumstances of her separation from the Company, any exit interview documentation, any severance or separation agreements, and any communications to, from, or concerning Whitcomb relevant to the subject matter of this hold.
7. Any allegations, complaints, reports, or concerns regarding sexual harassment, inappropriate conduct, hostile work environment, discrimination, or retaliation involving any APS employee, whether made formally through the Company's complaint procedures, informally to a manager or Human Resources representative, or through any other channel, including the AGMG Ethics & Compliance Hotline.
8. The Ethics & Compliance Hotline complaint filed on April 18, 2023 (Meridian Compliance Solutions LLC case reference MCS-1014-00001), including the original complaint, any intake notes, investigative memoranda, communications with the reporter, follow-up actions taken, and any related hotline reports filed before or after this date that concern the same or similar subject matter.
9. Any HR investigations, counseling, warnings, or disciplinary actions involving Marcus Hale, including without limitation the verbal counseling issued to Hale on or about August 2, 2021, any documentation of that counseling session, any follow-up actions or monitoring undertaken in connection therewith, and any other formal or informal disciplinary measures, performance improvement plans, or counseling sessions involving Hale during the Preservation Period.
10. Company off-site events, retreats, dinners, and production travel, including but not limited to the following:
• The off-site event held on February 17–18, 2023 at the Monarch Valley Resort, Ojai, California, including all planning documents, attendee lists, expense reports, photographs, communications regarding the event, and any incident reports or complaints arising from the event;
• The production trip to Vancouver, British Columbia in or around October 2022, including travel itineraries, attendee lists, expense reports, and any communications or complaints arising from or relating to that trip;
• The company dinner held on or about February 3, 2023, including planning documents, attendee lists, expense reports, and any communications or complaints arising from or relating to that dinner; and
• Any other off-site events, retreats, dinners, or production travel during the Preservation Period at which Hale was present and which may be relevant to the allegations described herein.
11. Performance reviews, personnel files, and employment records for Marcus Hale, Jenna Morales, Claire Ngo, Darren Whitfield, Cameron Briggs, and Serena Whitcomb, including all documents maintained in the Company's HRIS (Human Resources Information System), physical personnel files, and any records maintained by individual managers.
12. All policies, handbooks, and training materials relating to anti-harassment, anti-discrimination, anti-retaliation, and complaint procedures, including but not limited to:
• The AGMG Global Code of Conduct, Version 4.2, effective January 1, 2022, and all prior versions in effect during the Preservation Period;
• The APS Employee Handbook, California Supplement, revised March 15, 2022, in particular Sections 5.3 (Anti-Harassment Policy), 5.7 (Complaint Procedures), and 8.1 (Anti-Retaliation Policy), and all prior versions in effect during the Preservation Period;
• The AGMG Board Corporate Governance Guidelines, Section 12 (Executive Conduct and Oversight), and all prior versions in effect during the Preservation Period;
• All training materials, attendance records, and certifications relating to harassment prevention training required under California Government Code section 12950.1 and related regulations; and
• Any other Company policies, procedures, or guidelines relating to workplace conduct, ethics, or compliance that may be relevant to the subject matter of this hold.
B. Types of Documents and ESI
The following categories describe the types of documents and ESI that must be preserved. This list is illustrative and is intended to encompass all formats and media in which potentially relevant information may exist:
• Email communications: All emails (including sent, received, drafts, deleted items/trash folder, archived items, and items in any sub-folders) on the Company's email system (currently Outlook / Exchange), including all attachments. This encompasses both internal and external email communications.
• Instant messaging and collaboration platforms: All messages on Meridian Solutions (including direct messages, group channels, and private channels), Northgate Data Systems, or any other messaging or collaboration platform used by APS or its employees for business purposes. This includes any messages that have been archived, muted, or moved to inactive channels.
• Text messages and mobile communications: All SMS, MMS, Westmark Software, Meridian Services Inc., Harborline Technologies, Kestrel Data Systems, or other messaging application communications on Company-issued devices or personal devices used for Company business. Custodians who have used personal devices for business-related communications are required to preserve all such communications.
• Calendar entries: All calendar items, meeting invitations, meeting acceptances and declines, scheduling records, and associated notes or attachments, whether maintained in Outlook, Brightmoor Services Inc., or any other calendaring application.
• Documents and files: All word processing documents, spreadsheets, presentations, PDFs, memoranda, reports, notes, and other files, whether stored on local hard drives, network shared drives (including the APS shared drive and any departmental drives), cloud storage services (including Severin Services Inc., Aldermere Systems, Hollowell Health IT, Larkspur Technologies, or any other cloud storage platform), or personal devices used for Company business.
• Human resources records: Personnel files, performance evaluations, compensation records, bonus and incentive plan records, disciplinary records, counseling records, complaint files, investigation files, hotline logs, intake forms, exit interview notes, separation and release agreements, and any other HR documentation relevant to the subject matter described above.
• Voicemail: All voicemail messages, whether stored on Company phone systems (including desk phones, voicemail servers, and unified messaging systems) or personal devices used for Company business.
• Social media: Any business-related communications conducted through social media platforms, including but not limited to Westmark Health IT, Northpoint Services Inc., Ashford Systems, Kestrel Services Inc., and any other social media services, to the extent such communications relate to the subject matter of this hold.
• Physical/hard-copy documents: All paper files, handwritten notes, printed documents, physical correspondence, photographs, and any other tangible records relevant to the subject matter described above, wherever such materials are located, including in office files, desk drawers, filing cabinets, home offices, or any other location.
• Metadata: All metadata associated with the above categories of ESI must be preserved in its native format. Documents must not be printed to paper, converted to PDF, or otherwise altered or converted in a manner that would strip, modify, or destroy metadata. Metadata includes but is not limited to file creation dates, modification dates, author information, recipient information, file paths, and tracked changes or revision history.
• Backup tapes and systems: The IT department must ensure that any backup tapes, disaster-recovery archives, system snapshots, or other backup media containing materials within the scope of this hold are preserved and not overwritten, recycled, or destroyed. This includes both on-premises backup systems and cloud-based backup or archival services.
IV. Custodians
The following individuals are identified as custodians whose documents and ESI must be preserved pursuant to this litigation hold. Additional custodians may be identified and notified as the investigation proceeds, in coordination between Victor Gallegos and Calderwood & Harkness LLP. Each custodian listed below will receive a copy of this notice and is required to comply with all obligations described herein.
1. Marcus Hale — President, Aurelius Pacific Studios Inc. Mr. Hale has been placed on paid administrative leave effective May 3, 2023. His system access, including email, Meridian Solutions, VPN, and all Company network access, has been suspended as of that date. The IT department is directed to preserve all data associated with Mr. Hale's accounts and devices in place, in their current state, and to ensure that no data is deleted, overwritten, or modified. Mr. Hale's Company-issued devices (including laptop, mobile phone, and any other equipment) must be collected and secured by the IT department in coordination with Calderwood & Harkness LLP.
2. Jenna Morales — Vice President of Development, Aurelius Pacific Studios Inc.
3. Claire Ngo — Senior Director of Talent Relations, Aurelius Pacific Studios Inc.
4. Darren Whitfield — Senior Vice President of Physical Production, Aurelius Pacific Studios Inc.
5. Cameron Briggs — Senior Vice President of Production, Aurelius Pacific Studios Inc.
6. Victor Gallegos — Vice President of Human Resources, Aurelius Pacific Studios Inc.
7. Additional SVP-level direct reports of Marcus Hale, to be identified in coordination with Calderwood & Harkness LLP. Once identified, these individuals will be provided with a copy of this notice and will be subject to the same preservation obligations.
8. Any current or former employee who may be identified as a relevant witness during the course of the investigation. Such individuals will be notified and provided with a copy of this notice as they are identified.
Note Regarding Former Employees: With respect to Serena Whitcomb (former Executive Assistant to Marcus Hale, employed approximately April 2019 through September 2021) and any other former employees who may be relevant to this matter, all Company records, files, and ESI relating to those individuals that remain in the custody, possession, or control of the Company must be preserved. This includes, without limitation, personnel files, email archives, separation agreements, exit interview documentation, and any other records retained by the Company following the individual's separation. The Company does not have authority to direct former employees to preserve their personal records, but any Company records relating to former employees must be preserved in full.
V. Obligations of Custodians
Each custodian identified in Section IV above is personally responsible for ensuring the preservation of all materials within their custody, possession, or control that fall within the scope of this hold. The preservation obligation extends to all locations and devices where relevant materials may be stored, including Company systems, Company-issued devices, personal devices used for business purposes, home offices, personal email accounts used for business purposes, personal cloud storage accounts, and any other location where relevant materials may exist.
Specifically, each custodian must:
1. Immediately cease any destruction, deletion, or alteration of potentially relevant materials. This includes ceasing any manual deletion of emails, text messages, instant messages, voicemails, files, or any other documents or ESI that may fall within the scope of this hold. Do not "clean up," reorganize, or otherwise alter any files, folders, or communications.
2. Search for and identify all physical and electronic locations where relevant materials may be stored. This includes, without limitation:
• Company-issued laptops, desktops, and other computing devices;
• Company-issued mobile phones and tablets;
• Personal devices (phones, laptops, tablets) used for Company business;
• Home offices, including any paper files, notes, or documents stored at your residence;
• Personal email accounts (e.g., Northgate Software, Cascade Health IT, Ridgeline Technologies) used for any business-related communications;
• Personal cloud storage accounts (e.g., Hollowell Health IT, Larkspur Technologies, Meridian Systems) where business-related documents may be stored;
• USB drives, external hard drives, or other portable storage media; and
• Any other location where potentially relevant materials may exist.
3. Disable any auto-delete functions on email accounts, messaging applications (including Meridian Solutions, Meridian Services Inc., Harborline Technologies, and any other applications with message expiration or auto-delete features), and mobile devices. If you are unsure how to disable auto-delete functions, contact the IT department or Victor Gallegos immediately for assistance.
4. Preserve all relevant materials in their current location and format. Do not move, copy to a new format, reorganize, rename, or otherwise alter materials unless specifically directed to do so by Calderwood & Harkness LLP or Victor Gallegos. The goal is to maintain materials in their existing state to preserve their integrity, including all associated metadata.
5. Promptly notify Victor Gallegos if any relevant materials have already been deleted, destroyed, or are at risk of loss. If you are aware of any materials that were destroyed or deleted before or after the date of this notice that may fall within the scope of this hold, you must report this immediately. Similarly, if you become aware of any materials that are at risk of loss or destruction (for example, due to device malfunction, storage limitations, or any other reason), you must report this without delay so that appropriate steps can be taken to preserve such materials.
6. Do not discuss the substance of this litigation hold or the underlying investigation with other employees, other than as directed by Calderwood & Harkness LLP or Victor Gallegos. The integrity of the investigation depends on maintaining confidentiality. You should not discuss the contents of this notice, the fact that you received it, or any aspect of the underlying allegations with colleagues, subordinates, or any other individuals, except as necessary to comply with the instructions set forth herein or as directed by counsel. If you are approached by another employee with questions about the investigation or this hold, direct them to Victor Gallegos.
If at any time during the pendency of this litigation hold you become aware of additional materials that may fall within the scope of this hold, or if you have any doubt about whether particular materials should be preserved, you must err on the side of preservation and contact Victor Gallegos or Calderwood & Harkness LLP for guidance.
VI. IT Department Obligations
The APS Information Technology department, under the supervision of the Chief Information Officer or the most senior IT leader within APS, is directed to take the following actions immediately and to continue these measures for the duration of this litigation hold:
1. Suspend all auto-delete, auto-archive, or recycling routines for email (Outlook / Exchange), Meridian Solutions, Northgate Data Systems, and any other messaging or collaboration platforms in use at APS, for all custodians identified in Section IV above. This includes any Company-wide or departmental auto-purge schedules, mailbox size limitations that trigger automatic deletion, and any retention policies that would result in the automated destruction of data within the scope of this hold.
2. Preserve backup tapes and system images that may contain data within the Preservation Period (January 1, 2019 to the present). No backup tapes, disaster-recovery media, or system snapshots that contain or may contain data within the scope of this hold shall be overwritten, recycled, degaussed, or destroyed. The IT department shall maintain a current inventory of all backup media subject to this preservation directive.
3. Preserve the APS Meridian Solutions workspace data, including all channels (both public and private) and all direct messages for identified custodians. If Meridian Solutions data is subject to any data retention limits or automatic deletion policies, these must be suspended immediately. The IT department shall coordinate with Calderwood & Harkness LLP regarding the export and preservation of Meridian Solutions data as needed.
4. Ensure that the email account and all system access credentials for Marcus Hale (currently suspended due to his administrative leave status) remain preserved and accessible for forensic collection. Mr. Hale's email account, Meridian Solutions account, network home directory, Cobalt Ridge Systems or Aldermere Systems data, and any other data repositories associated with his accounts must not be deleted, purged, or modified in any way. All Company-issued devices assigned to Mr. Hale must be collected, secured, and stored in a manner that preserves their forensic integrity.
5. Cooperate with Linden Forensics Group Inc. (201 Mission Street, Suite 1400, San Francisco, CA 94105), the digital forensics firm retained by Calderwood & Harkness LLP, in connection with any forensic data collection, imaging, or analysis efforts. The IT department shall provide Linden Forensics Group with such access to Company systems, devices, and data as may be reasonably necessary to carry out forensic preservation and collection activities, subject to coordination with Calderwood & Harkness LLP.
6. Maintain chain-of-custody documentation for any data preserved, collected, or produced pursuant to this hold. All transfers of data, devices, or media must be documented with the date, time, individuals involved, description of materials, and purpose of the transfer. Chain-of-custody logs shall be maintained in a secure location and made available to Calderwood & Harkness LLP upon request.
7. Do not alter, modify, or reset any passwords or security settings for custodian accounts without prior written authorization from Victor Gallegos. Any changes to access controls, authentication credentials, or security configurations for custodian accounts could compromise the integrity of preserved data and must be coordinated with counsel.
The IT department should designate a single point of contact for all matters relating to this litigation hold and provide that individual's name and contact information to Victor Gallegos and Calderwood & Harkness LLP within two (2) business days of receipt of this notice.
VII. Consequences of Non-Compliance
The obligation to preserve relevant evidence when litigation or an investigation is pending or reasonably anticipated is a serious legal duty imposed by law. All recipients of this notice are expected to comply fully and promptly with every requirement set forth herein.
Failure to comply with this litigation hold may have severe consequences, including but not limited to the following:
• Adverse legal consequences for the Company: Spoliation of evidence — the destruction, alteration, or failure to preserve potentially relevant materials — may expose Aurelius Pacific Studios Inc. and Aurelius Global Media Group PLC to court-imposed sanctions, including adverse inference instructions (which permit a judge or jury to presume that destroyed evidence was unfavorable to the Company), monetary sanctions, issue preclusion, or, in extreme cases, default judgment or dismissal of claims. Spoliation may also give rise to independent tort claims and regulatory penalties.
• Disciplinary action against individuals: Any individual who intentionally or negligently destroys, conceals, alters, or fails to preserve documents or ESI within the scope of this hold will be subject to disciplinary action, up to and including termination of employment. The Company will not tolerate any interference with its preservation obligations or the integrity of the ongoing investigation.
If you have any questions regarding the scope of this hold, whether particular documents or ESI fall within its scope, or how to comply with any aspect of this notice, you must direct those questions immediately to:
• Victor Gallegos, Vice President of Human Resources, Aurelius Pacific Studios Inc., 3200 West Alameda Avenue, Suite 400, Burbank, CA 91505; or
• Devon Archer, Calderwood & Harkness LLP, 1999 Avenue of the Stars, Suite 2800, Los Angeles, CA 90067.
Do not attempt to resolve questions of scope or compliance on your own. When in doubt, preserve the materials in question and seek guidance from the contacts listed above.
VIII. Acknowledgment and Confirmation
Each recipient of this notice is required to confirm receipt and understanding of this Litigation Hold Notice by completing, signing, and returning the acknowledgment form below to Victor Gallegos, Vice President of Human Resources, within three (3) business days of receipt. The signed acknowledgment form may be delivered in person, by interoffice mail, or by email (scanned copy) to Victor Gallegos at the address set forth below.
Failure to return the signed acknowledgment within the required timeframe will be treated as a compliance concern and will be reported to Calderwood & Harkness LLP.
ACKNOWLEDGMENT OF RECEIPT — LITIGATION HOLD NOTICE
Aurelius Pacific Studios Inc.
Dated: May 2, 2023
I acknowledge receipt of this Litigation Hold Notice dated May 2, 2023. I understand my obligation to preserve all documents and electronically stored information described herein and will comply with its terms. I confirm that I have not destroyed, deleted, or altered any potentially relevant materials after the date of this notice. I further understand that I must comply with all requirements set forth in this notice and that failure to do so may result in disciplinary action, up to and including termination of employment, as well as adverse legal consequences for the Company.
Printed Name: ____________
Title / Position: ____________
Date of Receipt: ____________
Signature: ________
IX. Contact Information for Questions
All questions regarding the scope of materials to be preserved, how to handle specific documents or categories of ESI, technical issues with preservation (such as disabling auto-delete functions or preserving data on personal devices), or any other aspect of this litigation hold should be directed to one of the following contacts without delay:
Victor Gallegos Vice President of Human Resources Aurelius Pacific Studios Inc. 3200 West Alameda Avenue, Suite 400 Burbank, CA 91505
Devon Archer Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 2800 Los Angeles, CA 90067
When in doubt about whether a particular document, communication, or category of information falls within the scope of this hold, err on the side of preservation and contact one of the individuals listed above for guidance. Prompt communication is essential to ensure that the Company meets its legal obligations and that the integrity of the investigation is maintained.
PRIVILEGED AND CONFIDENTIAL — PREPARED AT THE DIRECTION OF COUNSEL — CALDERWOOD & HARKNESS LLP
Calderwood & Harkness LLP — Matter No. 1017-00005

PRIVILEGED AND CONFIDENTIAL — PREPARED AT THE DIRECTION OF COUNSEL

DOCUMENT PRESERVATION / LITIGATION HOLD NOTICE

AURELIUS PACIFIC STUDIOS INC.

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