1017-00005 · Aurelius Global Media Group · Witness Interviews

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PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT PREPARED AT THE DIRECTION OF COUNSEL

This memorandum is a privileged and confidential communication prepared by Calderwood & Harkness LLP at the direction of counsel in connection with an independent workplace investigation. It is protected by the attorney-client privilege and the work-product doctrine. This memorandum is not to be disclosed, distributed, copied, or otherwise disseminated without the prior written authorization of Calderwood & Harkness LLP and the General Counsel of Aurelius Global Media Group PLC. Any unauthorized disclosure may constitute a waiver of applicable privileges.

TO: Investigation File — Matter No. 1017-00005

FROM: Nadia Petrov, Associate, Calderwood & Harkness LLP

DATE: June 8, 2023

RE: Privileged Interview Memorandum — Cameron Briggs, Senior Vice President of Production, Aurelius Pacific Studios Inc.

SUBJECT MATTER: Independent Workplace Investigation — Allegations Concerning Marcus Hale, President, Aurelius Pacific Studios Inc.

I. Interview Overview

Witness: Cameron Briggs, Senior Vice President of Production, Aurelius Pacific Studios Inc.

Date of Interview: June 8, 2023

Location: Calderwood & Harkness LLP, Los Angeles Office, 1999 Avenue of the Stars, Suite 2800, Los Angeles, California 90067

Interviewer(s): Nadia Petrov, Associate, Calderwood & Harkness LLP. Devon Archer, Partner, Calderwood & Harkness LLP, was unavailable for this interview due to a scheduling conflict with a deposition in an unrelated matter. Petrov conducted the interview alone, consistent with the investigation protocol previously approved by Bernard Crawford, lead engagement partner.

Duration: Approximately two (2) hours and fifteen (15) minutes, commencing at approximately 10:00 a.m. Pacific Daylight Time and concluding at approximately 12:15 p.m. Pacific Daylight Time.

Counsel Present for Witness: None. Briggs was not separately represented by personal counsel. At the outset of the interview, Briggs was advised of his right to retain personal counsel. Briggs stated that he did not believe personal counsel was necessary and did not request the opportunity to consult with or retain counsel prior to or during the interview.

Upjohn Admonition: The Upjohn corporate representation admonition was administered at the outset of the interview, prior to any substantive questioning. Briggs was advised of the following:

(a) Calderwood & Harkness LLP represents Aurelius Global Media Group PLC (the "Company") in connection with this investigation. Calderwood & Harkness does not represent Briggs individually, and no attorney-client relationship exists between Calderwood & Harkness and Briggs.

(b) The purpose of the interview is to gather facts relevant to the Company's independent workplace investigation concerning allegations involving Marcus Hale, President of Aurelius Pacific Studios Inc.

(c) The communications during the interview are protected by the attorney-client privilege. However, that privilege belongs solely to the Company, not to Briggs. The Company, at its sole discretion, may choose to waive the privilege and disclose the contents of the interview to third parties, including government agencies, regulators, or other parties, without Briggs's consent.

(d) Briggs was instructed not to discuss the substance of the interview with other employees, co-workers, or any third parties, in order to preserve the integrity of the investigation and the Company's privilege.

(e) The Company expects Briggs's full cooperation and candor during the interview.

Briggs confirmed orally that he understood each of the foregoing admonitions and agreed to proceed with the interview on that basis.

Note Regarding This Memorandum: This memorandum reflects counsel's summary and analysis of the interview and is not intended to be, and should not be treated as, a verbatim transcript of the interview. Where direct quotations appear, they reflect language that was recorded contemporaneously in counsel's handwritten notes taken during the interview. All other statements attributed to Briggs represent counsel's best recollection and contemporaneous summary of the substance of Briggs's responses.

II. Witness Background

Full Name: Cameron Briggs

Title: Senior Vice President of Production, Aurelius Pacific Studios Inc. ("APS")

Office Location: APS Headquarters, 3200 West Alameda Avenue, Suite 400, Burbank, California 91505

Reporting Relationship: Briggs stated that he reports directly to Marcus Hale, President of Aurelius Pacific Studios Inc. Briggs confirmed that he is one of nine (9) Senior Vice Presidents who report directly to Hale. The other direct-report SVPs include, among others, Darren Whitfield (SVP of Physical Production), as well as SVPs overseeing post-production, business affairs, marketing, distribution, and other functional areas within APS. Briggs stated that each SVP has a defined area of responsibility but that there is occasional overlap and collaboration among the SVP group, particularly in physical production, where Briggs and Whitfield have adjacent portfolios.

Tenure at Aurelius Pacific Studios Inc.: Briggs stated that he has been employed by Aurelius Pacific Studios Inc. since approximately 2018. He initially joined the company in the role of Vice President of Production, a position he held for approximately two years. In or about 2020, Briggs was promoted to his current role of Senior Vice President of Production. Briggs stated that the promotion was approved by Hale and ratified by the corporate leadership of Aurelius Global Media Group PLC in London. Prior to joining APS, Briggs stated he had approximately twelve years of experience in physical production and line producing at various major studios and independent production companies, though the details of his prior employment were not explored in depth during this interview.

Responsibilities: Briggs described his role as overseeing physical production for a defined slate of film and streaming content projects within the APS production pipeline. His core responsibilities include production budgeting, scheduling, vendor and crew management, location coordination, and on-set production oversight. Briggs stated that he works closely with line producers, production managers, and department heads during the active production phase, and coordinates with post-production and business affairs during pre-production and wrap phases. Prior to February 2023, Briggs managed a portfolio of what he characterized as mid-budget productions — projects with individual budgets generally ranging from approximately $20 million to $55 million. After February 2023, his portfolio expanded significantly with the addition of Project Meridian and Project Halcyon, as discussed in detail in Section III below.

Relationship with Marcus Hale: Briggs described his working relationship with Hale as professional and largely positive. Briggs stated he considers Hale a "demanding but effective executive" who sets high expectations for his direct reports and is closely involved in production decisions. Briggs stated that Hale's management style could be "intense" and that Hale was known for being direct and, at times, brusque in his communications. Briggs stated that he has not had significant personal interactions with Hale outside of professional work contexts. Briggs noted that he has attended company social events and off-site retreats where Hale was present but stated that their interactions at those events remained largely professional. Briggs stated he did not consider himself to be in Hale's "inner circle" of trusted advisors and described his relationship with Hale as respectful but not close.

Relationship with Darren Whitfield: Briggs described Darren Whitfield, SVP of Physical Production, as a peer within the APS leadership team. Briggs stated that he and Whitfield have generally maintained a collegial and cooperative working relationship, particularly given the overlap between their respective production portfolios. Briggs stated that he and Whitfield occasionally differed on production approaches — for example, regarding preferred vendors, shooting locations, or scheduling methodologies — but characterized these disagreements as normal professional differences that did not rise to the level of personal conflict. Briggs stated that he was aware Whitfield had been with Aurelius Pacific Studios since approximately September 2017, predating Briggs's own arrival at the company, and that Whitfield was considered one of the most senior and experienced members of the production leadership group. Briggs stated he had respect for Whitfield's track record and capabilities.

III. Circumstances of the Project Reassignment

A. Notification of Reassignment

Briggs stated that on or about February 6, 2023, he was called into a meeting with Marcus Hale in Hale's office at the APS Burbank headquarters. Briggs stated that the meeting was not previously scheduled and that he received a call from Hale's executive assistant asking him to come to Hale's office, which he did within approximately fifteen to twenty minutes of receiving the call. Briggs stated he did not know the purpose of the meeting in advance and was not given any indication of the topic to be discussed.

During the meeting, Hale informed Briggs that two high-profile production projects — known internally by the codenames "Project Meridian" and "Project Halcyon" — were being reassigned from Darren Whitfield's oversight to Briggs's portfolio, effective immediately. Briggs stated that Hale presented the reassignment as a fait accompli and did not solicit Briggs's input on whether Briggs was willing or able to take on the additional projects prior to making the decision.

Briggs confirmed that the combined production budgets of Project Meridian and Project Halcyon were approximately $187 million. He described both projects as among the largest and most prominent productions in the APS slate for the current production cycle. Briggs stated that Project Meridian, in particular, was a tentpole feature film with significant corporate visibility and that it had been a priority for Hale and for Aurelius Global Media Group PLC's London leadership. Project Halcyon was described as a high-budget limited series being developed for a major streaming platform distribution partner.

Briggs stated that prior to this meeting with Hale, he had received no advance notice, warning, or indication — whether from Hale, from Whitfield, from HR, or from any other source — that the reassignment of these projects was being considered. Briggs stated the announcement "came as a surprise" to him.

B. Rationale Provided by Hale

Briggs stated that during the February 6, 2023 meeting, he asked Hale why the projects were being reassigned from Whitfield to Briggs. According to Briggs, Hale responded with words to the effect that "Darren's plate is too full and I need someone who can give these the bandwidth they require." Briggs stated that Hale characterized the reassignment as a "resource rebalancing" or "portfolio optimization" decision and framed it as a routine operational adjustment aimed at ensuring adequate executive attention for the two high-profile projects.

Briggs stated that Hale did not characterize the reassignment as a reflection of any performance issue on Whitfield's part. Hale did not mention any specific performance deficiencies, production delays, budget overruns, or quality concerns related to Whitfield's handling of either Project Meridian or Project Halcyon. Briggs stated that Hale's tone during the meeting was businesslike and that Hale did not express any frustration with or criticism of Whitfield.

Briggs stated that Hale did not reference any interpersonal issues, any complaints filed by or against any employee, or the January 23, 2023 leadership meeting in explaining the rationale for the reassignment. The January 23 meeting was not mentioned by Hale in any context during the February 6 conversation, according to Briggs.

When asked by the interviewer whether Hale's stated rationale struck him as unusual or insufficient, Briggs stated that project reassignments among SVPs were "not unheard of" within APS's operating structure. However, Briggs acknowledged that reassigning two flagship projects simultaneously — particularly projects of this combined scale and corporate visibility — was "uncommon" in his experience at APS. Briggs stated that in his approximately five years at the company, he could not recall a prior instance in which two projects of comparable magnitude were simultaneously transferred from one SVP to another. Briggs stated that if there had been a genuine capacity concern regarding Whitfield, he would have expected the issue to be discussed at a broader leadership level or through a more structured portfolio review process, rather than implemented through a single, unscheduled meeting.

C. Briggs's Understanding of Whitfield's Reaction

Briggs stated that after the reassignment was announced on February 6, 2023, he spoke briefly with Whitfield, either later that same day or on the following day. Briggs stated that Whitfield appeared "Upset" and "blindsided" by the decision. Briggs recalled that Whitfield said something to the effect that the decision "came out of nowhere" and that it did not make sense from a production continuity standpoint. Briggs stated that Whitfield expressed frustration about being removed from projects he had shepherded from the development phase through pre-production and into early production stages, and that Whitfield appeared personally and professionally hurt by the decision.

Briggs stated that during this conversation, Whitfield did not disclose to Briggs any connection between the reassignment and the January 23, 2023 leadership meeting, nor did Whitfield reference any complaints about Hale's conduct or any concerns about potential retaliation. Briggs stated the conversation was relatively brief and focused primarily on Whitfield's surprise at the decision and the logistical challenges of transferring project oversight mid-stream.

Briggs stated that he later became aware — after the formal investigation commenced in approximately late April or early May 2023 — that Whitfield believed the reassignment was retaliatory in nature, specifically that Whitfield believed Hale had stripped him of the two highest-profile projects in his portfolio as a direct consequence of Whitfield's comments at the January 23, 2023 leadership meeting concerning Hale's treatment of female employees. Briggs stated that he did not independently reach this conclusion prior to learning of Whitfield's retaliation allegation and that, at the time of the reassignment, he had not connected the two events.

D. Documentation and Transition

Briggs stated that there was no formal written memorandum, project-transition plan, or documented justification for the reassignment that he received from Hale, from HR, or from any other source within APS. Briggs stated the transition was handled informally: Hale directed Briggs to "get up to speed" on both projects as quickly as possible and separately directed Whitfield to hand over all project files, production schedules, vendor contracts, and related materials to Briggs.

Briggs stated that the actual transition of project files and institutional knowledge occurred over a period of approximately one to two weeks, during which Briggs and Whitfield had several working meetings to review the status of both productions. Briggs stated that Whitfield was cooperative during the transition process, notwithstanding his evident frustration with the decision.

Briggs stated that he found the lack of formal documentation somewhat unusual for a reassignment of this magnitude. He noted that in his experience, major portfolio changes at APS and at other studios where he had previously worked were typically accompanied by at least a written summary of the business rationale, a transition timeline, and coordination with human resources to ensure appropriate role adjustments and, if applicable, compensation changes. Briggs stated, however, that he did not raise these concerns with Hale or with anyone else at the time of the reassignment.

Briggs confirmed that he did not receive any communication from Victor Gallegos, Vice President of Human Resources, or from anyone else in the APS or Aurelius Global human resources function, regarding the reassignment — neither in advance of the reassignment, at the time of the reassignment, nor afterward. Briggs stated he was not aware of any HR review or approval process that was undertaken in connection with the reassignment.

IV. January 23, 2023 Leadership Meeting

Briggs confirmed that he attended the leadership team meeting on January 23, 2023. The meeting took place at the APS Burbank headquarters and was attended by Marcus Hale, Darren Whitfield, Briggs, and several other SVPs in Hale's direct-report group. Briggs stated that the meeting covered a range of routine production and operational topics, including slate updates, budget reviews, and distribution partner discussions.

When asked whether he recalled Whitfield raising concerns about Hale's treatment of female employees at that meeting, Briggs initially stated that he did not recall the specific comment in detail. Briggs stated that the meeting covered many topics and that he did not take detailed personal notes of the discussion.

Upon further questioning by the interviewer, Briggs stated that he had a "vague recollection" that Whitfield made a comment toward the end of the meeting. Briggs stated that his best recollection was that Whitfield's comment was something about "how we treat people" or "the culture on the executive floor," but Briggs stated he could not recall the precise words that Whitfield used. Briggs stated he could not recall with certainty whether Whitfield specifically referenced "female employees" or "women" in his comment, though Briggs acknowledged that the general thrust of the remark, as he recalled it, appeared to be directed at interpersonal treatment or workplace culture within the executive ranks.

Briggs stated that he did not recall Hale's specific reaction to Whitfield's comment at the meeting. Briggs stated generally that the meeting "ended on a tense note" and that there was an uncomfortable silence or shift in tone after Whitfield's comment, but Briggs was unable to provide further detail about Hale's verbal or nonverbal response. Briggs did not recall whether Hale addressed Whitfield's comment directly or whether the meeting simply concluded without further discussion of the topic.

Briggs stated that he did not connect Whitfield's comments at the January 23 meeting with the subsequent project reassignment on February 6, 2023, until after the investigation commenced. Briggs stated that at the time of the reassignment, approximately two weeks after the meeting, the connection between the two events did not occur to him. Briggs stated that it was only after learning of Whitfield's retaliation allegation that he reflected on the chronology and recognized the temporal proximity of the two events.

V. Briggs's Observations Regarding Hale's Conduct Generally

A. Interactions with Female Employees

Briggs was asked whether he had personally observed any conduct by Marcus Hale toward female employees that Briggs considered inappropriate or concerning. Briggs stated that he had not witnessed any conduct that he would characterize as sexual harassment.

However, Briggs provided the following additional context. Briggs stated that Hale's management style was "intense" across the board — with both male and female employees — and that Hale could be sharp, demanding, and, at times, dismissive in meetings and one-on-one interactions. Briggs stated that, separately from his general intensity, Hale could be "more familiar" in his interactions with some female colleagues than Briggs considered typical or appropriate in a professional setting. Briggs gave the specific example that Hale would sometimes comment on female employees' appearance in group settings — for example, remarking on clothing, hairstyles, or general appearance — in a way that Briggs described as "complimentary but maybe old-school." Briggs stated that these comments were not overtly sexual in nature but that they struck Briggs as reflecting a generational sensibility that was out of step with current workplace norms.

Briggs stated he could not recall specific instances or identify specific individuals who were the subject of such comments, beyond a general impression that the pattern was recurring. Briggs was not able to pinpoint specific dates, meetings, or events at which such comments occurred.

Briggs stated that he had never seen Hale engage in any physical contact with a female employee that appeared unwelcome or inappropriate. Briggs acknowledged, however, that he was not present at all of the events, meetings, private interactions, or social occasions referenced in the investigation, and that his observations were necessarily limited to those interactions he personally witnessed.

B. Knowledge of Complaints

Briggs was asked about his awareness of specific complaints that have been filed in connection with this investigation.

Briggs stated that he was not aware of the complaint filed by Jenna Morales, Director of Development at APS, on April 18, 2023, until after the investigation was formally announced by Aurelius Global Media Group PLC. Briggs stated he had no prior knowledge of the substance of Morales's allegations.

Briggs stated that he was similarly not aware of the complaint filed by Claire Ngo, Vice President of Content Strategy at APS, on April 24, 2023, until after the investigation was announced. Briggs stated he did not have regular professional interactions with Ngo and was not aware of the circumstances giving rise to her complaint.

Briggs was also asked about his awareness of any prior complaints against Hale. Briggs stated that he was not aware of the 2021 informal complaint filed by Serena Whitcomb, who had served as Hale's executive assistant. That complaint was reportedly filed in or around July 2021. Briggs stated that he did not know Whitcomb well, as she was Hale's direct executive assistant and Briggs's interactions with her were limited to routine scheduling and administrative coordination. Briggs stated he had no knowledge of the substance of Whitcomb's complaint or of any action taken in response to it.

C. Company Off-Site — Monarch Valley Resort (February 17–18, 2023)

Briggs confirmed that he attended the APS company off-site retreat held at the Monarch Valley Resort in Ojai, California, on February 17–18, 2023. Briggs stated that the off-site was a regularly scheduled annual event that brought together members of the APS leadership team and select department heads for strategy sessions, team-building activities, and social programming. Briggs estimated that approximately thirty-five to forty APS employees attended the off-site.

When asked whether he observed any interactions between Marcus Hale and Claire Ngo at the off-site, Briggs stated that he did not recall observing any specific interactions between Hale and Ngo that stood out to him or that he considered noteworthy at the time. Briggs stated that the off-site involved multiple group sessions, breakout discussions, and social events — including a group dinner on the evening of February 17 — and that he was not present for all conversations or interactions that occurred during the event. Briggs stated he could not rule out that Hale and Ngo interacted at the off-site, but he had no specific memory of any such interaction.

VI. Briggs's Observations Regarding Whitfield

Briggs was asked for his assessment of Darren Whitfield's professional capabilities and performance, particularly in connection with Project Meridian and Project Halcyon.

Briggs stated that Whitfield is a capable and experienced production executive with a strong track record at Aurelius Pacific Studios. Briggs stated he was "surprised" by the reassignment of Project Meridian and Project Halcyon from Whitfield to Briggs, given Whitfield's experience and his involvement with both projects from their inception. Briggs stated that Whitfield had been intimately involved in the development and pre-production of both projects and had built strong working relationships with the line producers, directors, and key creative personnel attached to each project.

Briggs stated that, to his knowledge, Whitfield had been performing well on both projects prior to the reassignment. Briggs stated he was not aware of any documented performance concerns, production delays, budget overruns, or quality issues regarding Whitfield's handling of either Project Meridian or Project Halcyon. Briggs stated that no one — including Hale — had communicated to him, either before or after the reassignment, any specific performance-related reason for removing Whitfield from the projects.

Briggs stated that after the reassignment, Whitfield appeared "demoralized" and that their professional relationship became somewhat strained. Briggs attributed this strain to the inherent awkwardness of inheriting a peer's projects under circumstances that Briggs himself did not fully understand, rather than to any personal dispute or animosity between the two of them. Briggs stated that he and Whitfield continued to interact professionally but that there was a perceptible distance in their working relationship that had not existed prior to February 2023. Briggs stated that he made an effort to be sensitive to the situation and did not seek to undermine or diminish Whitfield's prior contributions to the projects.

VII. Briggs's Interactions with Hale Regarding the Investigation

Briggs stated that following Marcus Hale's placement on paid administrative leave, effective May 3, 2023, Briggs received no further communications from Hale regarding any subject, whether related to the investigation, to ongoing APS business, or to personal matters. Briggs stated he had not spoken with Hale — by phone, email, text message, or in person — since Hale's leave commenced.

Briggs stated he had not spoken with Graham Thornfield of Thornfield & Associates LLP, who Briggs understood to be Hale's personal counsel in connection with the investigation. Briggs stated he had not been contacted by Thornfield or by any other representative of Hale, and that he had not initiated any such contact.

Briggs confirmed that he received the litigation hold notice issued by Aurelius Pacific Studios Inc. on or about May 2, 2023. Briggs stated that he reviewed the notice and understood his obligations to identify, preserve, and refrain from destroying or altering any documents, electronic communications, files, or other materials potentially relevant to the investigation. Briggs stated that he has complied with the litigation hold and has preserved all relevant documents and communications in his possession, custody, or control, including emails, calendar entries, text messages, and project files related to the reassignment of Project Meridian and Project Halcyon.

VIII. Documents Referenced

During the course of the interview, Briggs was shown several documents and asked to confirm their authenticity and to provide any additional context or recollection. The documents shown to Briggs included the following:

1. Email from Marcus Hale to Cameron Briggs, dated February 6, 2023. This email directed Briggs to assume oversight of Project Meridian and Project Halcyon, effective immediately. Briggs confirmed that he received this email on or about February 6, 2023, following his in-person meeting with Hale that same day. Briggs noted that the email was brief and contained no stated justification for the reassignment beyond the phrase "portfolio rebalancing." The email did not reference Whitfield by name, did not identify any performance concerns, and did not describe any formal review process underlying the decision. Briggs confirmed the authenticity of the email.

2. Email from Marcus Hale to Darren Whitfield, dated February 6, 2023, on which Briggs was copied. This email directed Whitfield to transition all project files, production schedules, vendor contracts, and related materials for Project Meridian and Project Halcyon to Briggs. Briggs confirmed that he was copied on this email and received it on or about February 6, 2023. The email was similarly brief and did not contain a detailed explanation for the reassignment. Briggs confirmed the authenticity of the email.

Briggs was asked whether he received or was aware of any other written communications — whether from Hale, from Victor Gallegos, from any other member of the HR team, or from any other source — that documented or explained the rationale for the reassignment. Briggs stated that he did not recall receiving any such communications and was not aware of any written documentation beyond the two emails described above.

IX. Additional Matters

At the conclusion of the substantive interview, Briggs was asked several additional questions.

Briggs was asked whether he had any concerns about participating in the investigation or any fear of retaliation — whether from Hale, from other members of APS leadership, or from any other source — as a result of his cooperation with the investigation. Briggs stated that he did not have any such concerns. Briggs stated that he understood the importance of the investigation and was willing to cooperate fully.

Briggs was asked whether there were any other facts, observations, documents, or information relevant to the investigation that he wished to share or that he believed the investigation team should be aware of. Briggs stated that he did not have additional information to share at this time but expressed his willingness to be re-interviewed if additional questions arose or if the investigation team needed further clarification on any topic discussed during the interview.

At the conclusion of the interview, Briggs was reminded of the Upjohn admonition administered at the outset and, specifically, of the instruction not to discuss the substance of the interview with other employees, co-workers, or third parties. Briggs confirmed his understanding of this instruction and agreed to comply.

The interview concluded at approximately 12:15 p.m. Pacific Daylight Time.

X. Assessment and Notes (Counsel's Internal Observations)

The following section contains counsel's internal assessments, mental impressions, and analytical observations regarding the interview. This section is protected attorney work product and reflects the thought processes and strategic evaluations of counsel. It should be treated with the highest degree of confidentiality and is intended solely for use by the Calderwood & Harkness investigation team and authorized representatives of Aurelius Global Media Group PLC.

Witness Demeanor and Credibility. Briggs appeared cooperative and forthcoming throughout the interview. He answered questions directly, provided responsive detail where he could, and candidly acknowledged the limits of his recollection where applicable. He did not appear evasive, defensive, or reluctant to discuss any topic raised during the interview. Briggs's demeanor was calm and professional. No credibility concerns were noted regarding this witness.

Consistency with Other Witness Accounts. Briggs's account is generally consistent with the account provided by Darren Whitfield regarding the circumstances of the reassignment of Project Meridian and Project Halcyon. In particular, Briggs's testimony corroborates the following aspects of Whitfield's account: (i) the reassignment was announced abruptly and without prior notice; (ii) Hale provided no performance-based or documented justification for the reassignment; (iii) the transition was handled informally, without HR involvement or formal documentation; and (iv) the reassignment involved two of the highest-profile projects in Whitfield's portfolio, representing a combined production budget of approximately $187 million.

Temporal Proximity and Absence of Documented Rationale. Briggs's testimony supports the finding that Hale provided no performance-based rationale for the reassignment of Project Meridian and Project Halcyon — the two highest-profile and largest-budget projects in Whitfield's portfolio — and that the reassignment occurred within approximately two weeks of the January 23, 2023 leadership meeting at which Whitfield raised concerns about Hale's treatment of female employees. While Briggs himself did not draw a causal connection between the two events at the time, his testimony — particularly regarding the absence of any stated performance concern, the lack of formal documentation, the unusual scale and simultaneity of the reassignment, and the absence of HR involvement — is circumstantially relevant to the assessment of Whitfield's retaliation allegation.

Contextual Background Regarding Hale's Conduct. Briggs's testimony that Hale's interpersonal style with female employees was "more familiar" than typical in a professional setting — including comments on female employees' appearance characterized as "complimentary but maybe old-school" — provides relevant contextual background for the investigation. While Briggs was careful to state that he would not characterize Hale's conduct as sexual harassment and did not identify specific incidents or individuals, the testimony suggests a pattern of conduct by Hale that was noticed by members of his leadership team and that may be consistent with the broader pattern alleged by Morales and Ngo.

Prior Complaint by Serena Whitcomb. Briggs's lack of awareness of the July 2021 informal complaint by former executive assistant Serena Whitcomb is consistent with the finding that the complaint was handled informally by Victor Gallegos, VP of Human Resources, with only a verbal counseling of Hale (approximately August 2, 2021) and no written documentation retained in Hale's personnel file. The fact that Briggs — a direct-report SVP to Hale and a member of the APS leadership team — was not aware of the Whitcomb complaint supports the conclusion that the complaint was not broadly communicated and that no formal corrective action visible to the leadership team was undertaken.

Areas for Follow-Up. Briggs's recollection of Whitfield's comment at the January 23 meeting — while characterized by Briggs as "vague" — is at least partially corroborative of Whitfield's account. However, Briggs's inability to recall the precise words used by Whitfield, and his uncertainty as to whether Whitfield specifically referenced "female employees," limits the corroborative weight of his testimony on this point. Corroboration from other attendees of the January 23 meeting should continue to be pursued. Briggs's general observations regarding Hale's appearance-related comments to female employees may warrant additional follow-up questioning if specific incidents or individuals can be identified through other witness interviews or documentary evidence.

PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT

Prepared by:

Nadia Petrov Associate Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 2800 Los Angeles, California 90067

Date: June 8, 2023

Reviewed by:

Devon Archer, Partner, Calderwood & Harkness LLP — [Review Pending]

Bernard Crawford, Partner (Lead Engagement Partner), Calderwood & Harkness LLP — [Review Pending]

Matter No.: 1017-00005

PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT. This memorandum was prepared by Calderwood & Harkness LLP at the direction of counsel in connection with the independent workplace investigation concerning Marcus Hale, President, Aurelius Pacific Studios Inc. It is not to be disclosed, distributed, copied, or otherwise disseminated without the prior written authorization of Calderwood & Harkness LLP and the General Counsel of Aurelius Global Media Group PLC.

PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT PREPARED AT THE DIRECTION OF COUNSEL
This memorandum is a privileged and confidential communication prepared by Calderwood & Harkness LLP at the direction of counsel in connection with an independent workplace investigation. It is protected by the attorney-client privilege and the work-product doctrine. This memorandum is not to be disclosed, distributed, copied, or otherwise disseminated without the prior written authorization of Calderwood & Harkness LLP and the General Counsel of Aurelius Global Media Group PLC. Any unauthorized disclosure may constitute a waiver of applicable privileges.
TO: Investigation File — Matter No. 1017-00005
FROM: Nadia Petrov, Associate, Calderwood & Harkness LLP
DATE: June 8, 2023
RE: Privileged Interview Memorandum — Cameron Briggs, Senior Vice President of Production, Aurelius Pacific Studios Inc.
SUBJECT MATTER: Independent Workplace Investigation — Allegations Concerning Marcus Hale, President, Aurelius Pacific Studios Inc.
I. Interview Overview
Witness: Cameron Briggs, Senior Vice President of Production, Aurelius Pacific Studios Inc.
Date of Interview: June 8, 2023
Location: Calderwood & Harkness LLP, Los Angeles Office, 1999 Avenue of the Stars, Suite 2800, Los Angeles, California 90067
Interviewer(s): Nadia Petrov, Associate, Calderwood & Harkness LLP. Devon Archer, Partner, Calderwood & Harkness LLP, was unavailable for this interview due to a scheduling conflict with a deposition in an unrelated matter. Petrov conducted the interview alone, consistent with the investigation protocol previously approved by Bernard Crawford, lead engagement partner.
Duration: Approximately two (2) hours and fifteen (15) minutes, commencing at approximately 10:00 a.m. Pacific Daylight Time and concluding at approximately 12:15 p.m. Pacific Daylight Time.
Counsel Present for Witness: None. Briggs was not separately represented by personal counsel. At the outset of the interview, Briggs was advised of his right to retain personal counsel. Briggs stated that he did not believe personal counsel was necessary and did not request the opportunity to consult with or retain counsel prior to or during the interview.
Upjohn Admonition: The Upjohn corporate representation admonition was administered at the outset of the interview, prior to any substantive questioning. Briggs was advised of the following:
(a) Calderwood & Harkness LLP represents Aurelius Global Media Group PLC (the "Company") in connection with this investigation. Calderwood & Harkness does not represent Briggs individually, and no attorney-client relationship exists between Calderwood & Harkness and Briggs.
(b) The purpose of the interview is to gather facts relevant to the Company's independent workplace investigation concerning allegations involving Marcus Hale, President of Aurelius Pacific Studios Inc.
(c) The communications during the interview are protected by the attorney-client privilege. However, that privilege belongs solely to the Company, not to Briggs. The Company, at its sole discretion, may choose to waive the privilege and disclose the contents of the interview to third parties, including government agencies, regulators, or other parties, without Briggs's consent.
(d) Briggs was instructed not to discuss the substance of the interview with other employees, co-workers, or any third parties, in order to preserve the integrity of the investigation and the Company's privilege.
(e) The Company expects Briggs's full cooperation and candor during the interview.
Briggs confirmed orally that he understood each of the foregoing admonitions and agreed to proceed with the interview on that basis.
Note Regarding This Memorandum: This memorandum reflects counsel's summary and analysis of the interview and is not intended to be, and should not be treated as, a verbatim transcript of the interview. Where direct quotations appear, they reflect language that was recorded contemporaneously in counsel's handwritten notes taken during the interview. All other statements attributed to Briggs represent counsel's best recollection and contemporaneous summary of the substance of Briggs's responses.
II. Witness Background
Full Name: Cameron Briggs
Title: Senior Vice President of Production, Aurelius Pacific Studios Inc. ("APS")
Office Location: APS Headquarters, 3200 West Alameda Avenue, Suite 400, Burbank, California 91505
Reporting Relationship: Briggs stated that he reports directly to Marcus Hale, President of Aurelius Pacific Studios Inc. Briggs confirmed that he is one of nine (9) Senior Vice Presidents who report directly to Hale. The other direct-report SVPs include, among others, Darren Whitfield (SVP of Physical Production), as well as SVPs overseeing post-production, business affairs, marketing, distribution, and other functional areas within APS. Briggs stated that each SVP has a defined area of responsibility but that there is occasional overlap and collaboration among the SVP group, particularly in physical production, where Briggs and Whitfield have adjacent portfolios.
Tenure at Aurelius Pacific Studios Inc.: Briggs stated that he has been employed by Aurelius Pacific Studios Inc. since approximately 2018. He initially joined the company in the role of Vice President of Production, a position he held for approximately two years. In or about 2020, Briggs was promoted to his current role of Senior Vice President of Production. Briggs stated that the promotion was approved by Hale and ratified by the corporate leadership of Aurelius Global Media Group PLC in London. Prior to joining APS, Briggs stated he had approximately twelve years of experience in physical production and line producing at various major studios and independent production companies, though the details of his prior employment were not explored in depth during this interview.
Responsibilities: Briggs described his role as overseeing physical production for a defined slate of film and streaming content projects within the APS production pipeline. His core responsibilities include production budgeting, scheduling, vendor and crew management, location coordination, and on-set production oversight. Briggs stated that he works closely with line producers, production managers, and department heads during the active production phase, and coordinates with post-production and business affairs during pre-production and wrap phases. Prior to February 2023, Briggs managed a portfolio of what he characterized as mid-budget productions — projects with individual budgets generally ranging from approximately $20 million to $55 million. After February 2023, his portfolio expanded significantly with the addition of Project Meridian and Project Halcyon, as discussed in detail in Section III below.
Relationship with Marcus Hale: Briggs described his working relationship with Hale as professional and largely positive. Briggs stated he considers Hale a "demanding but effective executive" who sets high expectations for his direct reports and is closely involved in production decisions. Briggs stated that Hale's management style could be "intense" and that Hale was known for being direct and, at times, brusque in his communications. Briggs stated that he has not had significant personal interactions with Hale outside of professional work contexts. Briggs noted that he has attended company social events and off-site retreats where Hale was present but stated that their interactions at those events remained largely professional. Briggs stated he did not consider himself to be in Hale's "inner circle" of trusted advisors and described his relationship with Hale as respectful but not close.
Relationship with Darren Whitfield: Briggs described Darren Whitfield, SVP of Physical Production, as a peer within the APS leadership team. Briggs stated that he and Whitfield have generally maintained a collegial and cooperative working relationship, particularly given the overlap between their respective production portfolios. Briggs stated that he and Whitfield occasionally differed on production approaches — for example, regarding preferred vendors, shooting locations, or scheduling methodologies — but characterized these disagreements as normal professional differences that did not rise to the level of personal conflict. Briggs stated that he was aware Whitfield had been with Aurelius Pacific Studios since approximately September 2017, predating Briggs's own arrival at the company, and that Whitfield was considered one of the most senior and experienced members of the production leadership group. Briggs stated he had respect for Whitfield's track record and capabilities.
III. Circumstances of the Project Reassignment
A. Notification of Reassignment
Briggs stated that on or about February 6, 2023, he was called into a meeting with Marcus Hale in Hale's office at the APS Burbank headquarters. Briggs stated that the meeting was not previously scheduled and that he received a call from Hale's executive assistant asking him to come to Hale's office, which he did within approximately fifteen to twenty minutes of receiving the call. Briggs stated he did not know the purpose of the meeting in advance and was not given any indication of the topic to be discussed.
During the meeting, Hale informed Briggs that two high-profile production projects — known internally by the codenames "Project Meridian" and "Project Halcyon" — were being reassigned from Darren Whitfield's oversight to Briggs's portfolio, effective immediately. Briggs stated that Hale presented the reassignment as a fait accompli and did not solicit Briggs's input on whether Briggs was willing or able to take on the additional projects prior to making the decision.
Briggs confirmed that the combined production budgets of Project Meridian and Project Halcyon were approximately $187 million. He described both projects as among the largest and most prominent productions in the APS slate for the current production cycle. Briggs stated that Project Meridian, in particular, was a tentpole feature film with significant corporate visibility and that it had been a priority for Hale and for Aurelius Global Media Group PLC's London leadership. Project Halcyon was described as a high-budget limited series being developed for a major streaming platform distribution partner.
Briggs stated that prior to this meeting with Hale, he had received no advance notice, warning, or indication — whether from Hale, from Whitfield, from HR, or from any other source — that the reassignment of these projects was being considered. Briggs stated the announcement "came as a surprise" to him.
B. Rationale Provided by Hale
Briggs stated that during the February 6, 2023 meeting, he asked Hale why the projects were being reassigned from Whitfield to Briggs. According to Briggs, Hale responded with words to the effect that "Darren's plate is too full and I need someone who can give these the bandwidth they require." Briggs stated that Hale characterized the reassignment as a "resource rebalancing" or "portfolio optimization" decision and framed it as a routine operational adjustment aimed at ensuring adequate executive attention for the two high-profile projects.
Briggs stated that Hale did not characterize the reassignment as a reflection of any performance issue on Whitfield's part. Hale did not mention any specific performance deficiencies, production delays, budget overruns, or quality concerns related to Whitfield's handling of either Project Meridian or Project Halcyon. Briggs stated that Hale's tone during the meeting was businesslike and that Hale did not express any frustration with or criticism of Whitfield.
Briggs stated that Hale did not reference any interpersonal issues, any complaints filed by or against any employee, or the January 23, 2023 leadership meeting in explaining the rationale for the reassignment. The January 23 meeting was not mentioned by Hale in any context during the February 6 conversation, according to Briggs.
When asked by the interviewer whether Hale's stated rationale struck him as unusual or insufficient, Briggs stated that project reassignments among SVPs were "not unheard of" within APS's operating structure. However, Briggs acknowledged that reassigning two flagship projects simultaneously — particularly projects of this combined scale and corporate visibility — was "uncommon" in his experience at APS. Briggs stated that in his approximately five years at the company, he could not recall a prior instance in which two projects of comparable magnitude were simultaneously transferred from one SVP to another. Briggs stated that if there had been a genuine capacity concern regarding Whitfield, he would have expected the issue to be discussed at a broader leadership level or through a more structured portfolio review process, rather than implemented through a single, unscheduled meeting.
C. Briggs's Understanding of Whitfield's Reaction
Briggs stated that after the reassignment was announced on February 6, 2023, he spoke briefly with Whitfield, either later that same day or on the following day. Briggs stated that Whitfield appeared "Upset" and "blindsided" by the decision. Briggs recalled that Whitfield said something to the effect that the decision "came out of nowhere" and that it did not make sense from a production continuity standpoint. Briggs stated that Whitfield expressed frustration about being removed from projects he had shepherded from the development phase through pre-production and into early production stages, and that Whitfield appeared personally and professionally hurt by the decision.
Briggs stated that during this conversation, Whitfield did not disclose to Briggs any connection between the reassignment and the January 23, 2023 leadership meeting, nor did Whitfield reference any complaints about Hale's conduct or any concerns about potential retaliation. Briggs stated the conversation was relatively brief and focused primarily on Whitfield's surprise at the decision and the logistical challenges of transferring project oversight mid-stream.
Briggs stated that he later became aware — after the formal investigation commenced in approximately late April or early May 2023 — that Whitfield believed the reassignment was retaliatory in nature, specifically that Whitfield believed Hale had stripped him of the two highest-profile projects in his portfolio as a direct consequence of Whitfield's comments at the January 23, 2023 leadership meeting concerning Hale's treatment of female employees. Briggs stated that he did not independently reach this conclusion prior to learning of Whitfield's retaliation allegation and that, at the time of the reassignment, he had not connected the two events.
D. Documentation and Transition
Briggs stated that there was no formal written memorandum, project-transition plan, or documented justification for the reassignment that he received from Hale, from HR, or from any other source within APS. Briggs stated the transition was handled informally: Hale directed Briggs to "get up to speed" on both projects as quickly as possible and separately directed Whitfield to hand over all project files, production schedules, vendor contracts, and related materials to Briggs.
Briggs stated that the actual transition of project files and institutional knowledge occurred over a period of approximately one to two weeks, during which Briggs and Whitfield had several working meetings to review the status of both productions. Briggs stated that Whitfield was cooperative during the transition process, notwithstanding his evident frustration with the decision.
Briggs stated that he found the lack of formal documentation somewhat unusual for a reassignment of this magnitude. He noted that in his experience, major portfolio changes at APS and at other studios where he had previously worked were typically accompanied by at least a written summary of the business rationale, a transition timeline, and coordination with human resources to ensure appropriate role adjustments and, if applicable, compensation changes. Briggs stated, however, that he did not raise these concerns with Hale or with anyone else at the time of the reassignment.
Briggs confirmed that he did not receive any communication from Victor Gallegos, Vice President of Human Resources, or from anyone else in the APS or Aurelius Global human resources function, regarding the reassignment — neither in advance of the reassignment, at the time of the reassignment, nor afterward. Briggs stated he was not aware of any HR review or approval process that was undertaken in connection with the reassignment.
IV. January 23, 2023 Leadership Meeting
Briggs confirmed that he attended the leadership team meeting on January 23, 2023. The meeting took place at the APS Burbank headquarters and was attended by Marcus Hale, Darren Whitfield, Briggs, and several other SVPs in Hale's direct-report group. Briggs stated that the meeting covered a range of routine production and operational topics, including slate updates, budget reviews, and distribution partner discussions.
When asked whether he recalled Whitfield raising concerns about Hale's treatment of female employees at that meeting, Briggs initially stated that he did not recall the specific comment in detail. Briggs stated that the meeting covered many topics and that he did not take detailed personal notes of the discussion.
Upon further questioning by the interviewer, Briggs stated that he had a "vague recollection" that Whitfield made a comment toward the end of the meeting. Briggs stated that his best recollection was that Whitfield's comment was something about "how we treat people" or "the culture on the executive floor," but Briggs stated he could not recall the precise words that Whitfield used. Briggs stated he could not recall with certainty whether Whitfield specifically referenced "female employees" or "women" in his comment, though Briggs acknowledged that the general thrust of the remark, as he recalled it, appeared to be directed at interpersonal treatment or workplace culture within the executive ranks.
Briggs stated that he did not recall Hale's specific reaction to Whitfield's comment at the meeting. Briggs stated generally that the meeting "ended on a tense note" and that there was an uncomfortable silence or shift in tone after Whitfield's comment, but Briggs was unable to provide further detail about Hale's verbal or nonverbal response. Briggs did not recall whether Hale addressed Whitfield's comment directly or whether the meeting simply concluded without further discussion of the topic.
Briggs stated that he did not connect Whitfield's comments at the January 23 meeting with the subsequent project reassignment on February 6, 2023, until after the investigation commenced. Briggs stated that at the time of the reassignment, approximately two weeks after the meeting, the connection between the two events did not occur to him. Briggs stated that it was only after learning of Whitfield's retaliation allegation that he reflected on the chronology and recognized the temporal proximity of the two events.
V. Briggs's Observations Regarding Hale's Conduct Generally
A. Interactions with Female Employees
Briggs was asked whether he had personally observed any conduct by Marcus Hale toward female employees that Briggs considered inappropriate or concerning. Briggs stated that he had not witnessed any conduct that he would characterize as sexual harassment.
However, Briggs provided the following additional context. Briggs stated that Hale's management style was "intense" across the board — with both male and female employees — and that Hale could be sharp, demanding, and, at times, dismissive in meetings and one-on-one interactions. Briggs stated that, separately from his general intensity, Hale could be "more familiar" in his interactions with some female colleagues than Briggs considered typical or appropriate in a professional setting. Briggs gave the specific example that Hale would sometimes comment on female employees' appearance in group settings — for example, remarking on clothing, hairstyles, or general appearance — in a way that Briggs described as "complimentary but maybe old-school." Briggs stated that these comments were not overtly sexual in nature but that they struck Briggs as reflecting a generational sensibility that was out of step with current workplace norms.
Briggs stated he could not recall specific instances or identify specific individuals who were the subject of such comments, beyond a general impression that the pattern was recurring. Briggs was not able to pinpoint specific dates, meetings, or events at which such comments occurred.
Briggs stated that he had never seen Hale engage in any physical contact with a female employee that appeared unwelcome or inappropriate. Briggs acknowledged, however, that he was not present at all of the events, meetings, private interactions, or social occasions referenced in the investigation, and that his observations were necessarily limited to those interactions he personally witnessed.
B. Knowledge of Complaints
Briggs was asked about his awareness of specific complaints that have been filed in connection with this investigation.
Briggs stated that he was not aware of the complaint filed by Jenna Morales, Director of Development at APS, on April 18, 2023, until after the investigation was formally announced by Aurelius Global Media Group PLC. Briggs stated he had no prior knowledge of the substance of Morales's allegations.
Briggs stated that he was similarly not aware of the complaint filed by Claire Ngo, Vice President of Content Strategy at APS, on April 24, 2023, until after the investigation was announced. Briggs stated he did not have regular professional interactions with Ngo and was not aware of the circumstances giving rise to her complaint.
Briggs was also asked about his awareness of any prior complaints against Hale. Briggs stated that he was not aware of the 2021 informal complaint filed by Serena Whitcomb, who had served as Hale's executive assistant. That complaint was reportedly filed in or around July 2021. Briggs stated that he did not know Whitcomb well, as she was Hale's direct executive assistant and Briggs's interactions with her were limited to routine scheduling and administrative coordination. Briggs stated he had no knowledge of the substance of Whitcomb's complaint or of any action taken in response to it.
C. Company Off-Site — Monarch Valley Resort (February 17–18, 2023)
Briggs confirmed that he attended the APS company off-site retreat held at the Monarch Valley Resort in Ojai, California, on February 17–18, 2023. Briggs stated that the off-site was a regularly scheduled annual event that brought together members of the APS leadership team and select department heads for strategy sessions, team-building activities, and social programming. Briggs estimated that approximately thirty-five to forty APS employees attended the off-site.
When asked whether he observed any interactions between Marcus Hale and Claire Ngo at the off-site, Briggs stated that he did not recall observing any specific interactions between Hale and Ngo that stood out to him or that he considered noteworthy at the time. Briggs stated that the off-site involved multiple group sessions, breakout discussions, and social events — including a group dinner on the evening of February 17 — and that he was not present for all conversations or interactions that occurred during the event. Briggs stated he could not rule out that Hale and Ngo interacted at the off-site, but he had no specific memory of any such interaction.
VI. Briggs's Observations Regarding Whitfield
Briggs was asked for his assessment of Darren Whitfield's professional capabilities and performance, particularly in connection with Project Meridian and Project Halcyon.
Briggs stated that Whitfield is a capable and experienced production executive with a strong track record at Aurelius Pacific Studios. Briggs stated he was "surprised" by the reassignment of Project Meridian and Project Halcyon from Whitfield to Briggs, given Whitfield's experience and his involvement with both projects from their inception. Briggs stated that Whitfield had been intimately involved in the development and pre-production of both projects and had built strong working relationships with the line producers, directors, and key creative personnel attached to each project.
Briggs stated that, to his knowledge, Whitfield had been performing well on both projects prior to the reassignment. Briggs stated he was not aware of any documented performance concerns, production delays, budget overruns, or quality issues regarding Whitfield's handling of either Project Meridian or Project Halcyon. Briggs stated that no one — including Hale — had communicated to him, either before or after the reassignment, any specific performance-related reason for removing Whitfield from the projects.
Briggs stated that after the reassignment, Whitfield appeared "demoralized" and that their professional relationship became somewhat strained. Briggs attributed this strain to the inherent awkwardness of inheriting a peer's projects under circumstances that Briggs himself did not fully understand, rather than to any personal dispute or animosity between the two of them. Briggs stated that he and Whitfield continued to interact professionally but that there was a perceptible distance in their working relationship that had not existed prior to February 2023. Briggs stated that he made an effort to be sensitive to the situation and did not seek to undermine or diminish Whitfield's prior contributions to the projects.
VII. Briggs's Interactions with Hale Regarding the Investigation
Briggs stated that following Marcus Hale's placement on paid administrative leave, effective May 3, 2023, Briggs received no further communications from Hale regarding any subject, whether related to the investigation, to ongoing APS business, or to personal matters. Briggs stated he had not spoken with Hale — by phone, email, text message, or in person — since Hale's leave commenced.
Briggs stated he had not spoken with Graham Thornfield of Thornfield & Associates LLP, who Briggs understood to be Hale's personal counsel in connection with the investigation. Briggs stated he had not been contacted by Thornfield or by any other representative of Hale, and that he had not initiated any such contact.
Briggs confirmed that he received the litigation hold notice issued by Aurelius Pacific Studios Inc. on or about May 2, 2023. Briggs stated that he reviewed the notice and understood his obligations to identify, preserve, and refrain from destroying or altering any documents, electronic communications, files, or other materials potentially relevant to the investigation. Briggs stated that he has complied with the litigation hold and has preserved all relevant documents and communications in his possession, custody, or control, including emails, calendar entries, text messages, and project files related to the reassignment of Project Meridian and Project Halcyon.
VIII. Documents Referenced
During the course of the interview, Briggs was shown several documents and asked to confirm their authenticity and to provide any additional context or recollection. The documents shown to Briggs included the following:
1.  Email from Marcus Hale to Cameron Briggs, dated February 6, 2023. This email directed Briggs to assume oversight of Project Meridian and Project Halcyon, effective immediately. Briggs confirmed that he received this email on or about February 6, 2023, following his in-person meeting with Hale that same day. Briggs noted that the email was brief and contained no stated justification for the reassignment beyond the phrase "portfolio rebalancing." The email did not reference Whitfield by name, did not identify any performance concerns, and did not describe any formal review process underlying the decision. Briggs confirmed the authenticity of the email.
2.  Email from Marcus Hale to Darren Whitfield, dated February 6, 2023, on which Briggs was copied. This email directed Whitfield to transition all project files, production schedules, vendor contracts, and related materials for Project Meridian and Project Halcyon to Briggs. Briggs confirmed that he was copied on this email and received it on or about February 6, 2023. The email was similarly brief and did not contain a detailed explanation for the reassignment. Briggs confirmed the authenticity of the email.
Briggs was asked whether he received or was aware of any other written communications — whether from Hale, from Victor Gallegos, from any other member of the HR team, or from any other source — that documented or explained the rationale for the reassignment. Briggs stated that he did not recall receiving any such communications and was not aware of any written documentation beyond the two emails described above.
IX. Additional Matters
At the conclusion of the substantive interview, Briggs was asked several additional questions.
Briggs was asked whether he had any concerns about participating in the investigation or any fear of retaliation — whether from Hale, from other members of APS leadership, or from any other source — as a result of his cooperation with the investigation. Briggs stated that he did not have any such concerns. Briggs stated that he understood the importance of the investigation and was willing to cooperate fully.
Briggs was asked whether there were any other facts, observations, documents, or information relevant to the investigation that he wished to share or that he believed the investigation team should be aware of. Briggs stated that he did not have additional information to share at this time but expressed his willingness to be re-interviewed if additional questions arose or if the investigation team needed further clarification on any topic discussed during the interview.
At the conclusion of the interview, Briggs was reminded of the Upjohn admonition administered at the outset and, specifically, of the instruction not to discuss the substance of the interview with other employees, co-workers, or third parties. Briggs confirmed his understanding of this instruction and agreed to comply.
The interview concluded at approximately 12:15 p.m. Pacific Daylight Time.
X. Assessment and Notes (Counsel's Internal Observations)
The following section contains counsel's internal assessments, mental impressions, and analytical observations regarding the interview. This section is protected attorney work product and reflects the thought processes and strategic evaluations of counsel. It should be treated with the highest degree of confidentiality and is intended solely for use by the Calderwood & Harkness investigation team and authorized representatives of Aurelius Global Media Group PLC.
Witness Demeanor and Credibility. Briggs appeared cooperative and forthcoming throughout the interview. He answered questions directly, provided responsive detail where he could, and candidly acknowledged the limits of his recollection where applicable. He did not appear evasive, defensive, or reluctant to discuss any topic raised during the interview. Briggs's demeanor was calm and professional. No credibility concerns were noted regarding this witness.
Consistency with Other Witness Accounts. Briggs's account is generally consistent with the account provided by Darren Whitfield regarding the circumstances of the reassignment of Project Meridian and Project Halcyon. In particular, Briggs's testimony corroborates the following aspects of Whitfield's account: (i) the reassignment was announced abruptly and without prior notice; (ii) Hale provided no performance-based or documented justification for the reassignment; (iii) the transition was handled informally, without HR involvement or formal documentation; and (iv) the reassignment involved two of the highest-profile projects in Whitfield's portfolio, representing a combined production budget of approximately $187 million.
Temporal Proximity and Absence of Documented Rationale. Briggs's testimony supports the finding that Hale provided no performance-based rationale for the reassignment of Project Meridian and Project Halcyon — the two highest-profile and largest-budget projects in Whitfield's portfolio — and that the reassignment occurred within approximately two weeks of the January 23, 2023 leadership meeting at which Whitfield raised concerns about Hale's treatment of female employees. While Briggs himself did not draw a causal connection between the two events at the time, his testimony — particularly regarding the absence of any stated performance concern, the lack of formal documentation, the unusual scale and simultaneity of the reassignment, and the absence of HR involvement — is circumstantially relevant to the assessment of Whitfield's retaliation allegation.
Contextual Background Regarding Hale's Conduct. Briggs's testimony that Hale's interpersonal style with female employees was "more familiar" than typical in a professional setting — including comments on female employees' appearance characterized as "complimentary but maybe old-school" — provides relevant contextual background for the investigation. While Briggs was careful to state that he would not characterize Hale's conduct as sexual harassment and did not identify specific incidents or individuals, the testimony suggests a pattern of conduct by Hale that was noticed by members of his leadership team and that may be consistent with the broader pattern alleged by Morales and Ngo.
Prior Complaint by Serena Whitcomb. Briggs's lack of awareness of the July 2021 informal complaint by former executive assistant Serena Whitcomb is consistent with the finding that the complaint was handled informally by Victor Gallegos, VP of Human Resources, with only a verbal counseling of Hale (approximately August 2, 2021) and no written documentation retained in Hale's personnel file. The fact that Briggs — a direct-report SVP to Hale and a member of the APS leadership team — was not aware of the Whitcomb complaint supports the conclusion that the complaint was not broadly communicated and that no formal corrective action visible to the leadership team was undertaken.
Areas for Follow-Up. Briggs's recollection of Whitfield's comment at the January 23 meeting — while characterized by Briggs as "vague" — is at least partially corroborative of Whitfield's account. However, Briggs's inability to recall the precise words used by Whitfield, and his uncertainty as to whether Whitfield specifically referenced "female employees," limits the corroborative weight of his testimony on this point. Corroboration from other attendees of the January 23 meeting should continue to be pursued. Briggs's general observations regarding Hale's appearance-related comments to female employees may warrant additional follow-up questioning if specific incidents or individuals can be identified through other witness interviews or documentary evidence.
PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT
Prepared by:
Nadia Petrov Associate Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 2800 Los Angeles, California 90067
Date: June 8, 2023
Reviewed by:
Devon Archer, Partner, Calderwood & Harkness LLP — [Review Pending]
Bernard Crawford, Partner (Lead Engagement Partner), Calderwood & Harkness LLP — [Review Pending]
Matter No.: 1017-00005
PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT. This memorandum was prepared by Calderwood & Harkness LLP at the direction of counsel in connection with the independent workplace investigation concerning Marcus Hale, President, Aurelius Pacific Studios Inc. It is not to be disclosed, distributed, copied, or otherwise disseminated without the prior written authorization of Calderwood & Harkness LLP and the General Counsel of Aurelius Global Media Group PLC.

PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT PREPARED AT THE DIRECTION OF COUNSEL

PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT

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