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

Do Not Distribute or Copy Without Prior Authorization of Calderwood & Harkness LLP. This memorandum was prepared in anticipation of litigation and at the direction of counsel. It is protected from disclosure by the attorney-client privilege, the work product doctrine, and all other applicable privileges. Any unauthorized review, use, disclosure, or distribution of this document is strictly prohibited.

MEMORANDUM

TO: Investigation File — Matter No. 1017-00005

FROM: Devon Archer, Lead Associate, and Nadia Petrov, Associate, Calderwood & Harkness LLP

DATE: May 22, 2023

RE: Privileged Interview Summary — Jenna Morales, Vice President of Development, Aurelius Pacific Studios Inc.

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

I. Interview Details

A. Date, Time, and Location

The interview of Jenna Morales was conducted on May 22, 2023, which constituted the first day of witness interviews in the independent investigation authorized by the People & Culture Committee and the Audit & Risk Committee of the Board of Directors of Aurelius Global Media Group PLC ("AGMG"). The interview took place at the Los Angeles office of Calderwood & Harkness LLP, located at 1999 Avenue of the Stars, Suite 2800, Los Angeles, California 90067. A conference room on the twenty-eighth floor was reserved for the interview to ensure privacy and confidentiality.

The interview commenced at approximately 10:00 a.m. Pacific Time and concluded at approximately 1:45 p.m. Pacific Time, for a total duration of approximately three hours and forty-five minutes. This included a short break of approximately fifteen minutes, taken at approximately 11:50 a.m. at the request of the interviewee. During the break, no substantive matters were discussed. Light refreshments were available throughout the session.

B. Attendees

The following individuals were present for the interview:

• Jenna Morales, Vice President of Development, Aurelius Pacific Studios Inc. ("APS") — interviewee

• Devon Archer, Lead Associate, Calderwood & Harkness LLP — primary interviewer

• Nadia Petrov, Associate, Calderwood & Harkness LLP — note-taker and secondary interviewer

No other individuals were present in the interview room at any point during the session. The interview was not audio- or video-recorded, consistent with the firm's standard practice for internal investigation witness interviews.

C. Counsel Notification

Sandra Reeves, Partner at Nakamura Reeves LLP, 515 South Flower Street, Suite 3600, Los Angeles, California 90071, is outside counsel retained by Ms. Morales in connection with the matters under investigation. Ms. Reeves was notified of the interview in advance pursuant to Calderwood & Harkness's letter to Nakamura Reeves LLP dated May 10, 2023, which set forth the date, time, location, and general scope of the interview, as well as the applicable privilege framework and the Upjohn admonition that would be administered.

Ms. Reeves elected not to attend the interview. In a written response dated May 12, 2023, Ms. Reeves confirmed Ms. Morales's willingness to participate in the interview voluntarily and requested that any follow-up questions or requests for additional information be directed through her office rather than directly to Ms. Morales. Calderwood & Harkness agreed to this protocol. At the outset of the interview, Ms. Morales confirmed verbally that she was participating voluntarily and that she understood Ms. Reeves had chosen not to attend.

D. Upjohn Admonition

At the outset of the interview, and before any substantive questions were posed, Devon Archer administered the standard Upjohn / corporate counsel admonition consistent with Calderwood & Harkness's template script used in internal investigations. The admonition was delivered orally, and Ms. Morales was afforded the opportunity to ask questions before proceeding.

Specifically, Ms. Morales was advised of the following:

(1) Calderwood & Harkness LLP represents Aurelius Global Media Group PLC and its Board of Directors in connection with this investigation. Calderwood & Harkness does not represent Ms. Morales individually, and no attorney-client relationship exists between Calderwood & Harkness and Ms. Morales.

(2) The interview and the communications taking place during the interview are protected by the attorney-client privilege, which belongs solely to the company (AGMG and its Board of Directors). The privilege does not belong to Ms. Morales.

(3) The company may choose to waive or not to waive the attorney-client privilege at its sole discretion, including by disclosing the contents of this interview to third parties, government regulators, or in the context of litigation, without Ms. Morales's consent.

(4) Ms. Morales should keep the substance of the interview confidential and should not discuss the interview or the content of her statements with coworkers, other employees of APS or AGMG, or any other individuals, other than her personal counsel, Sandra Reeves.

Ms. Morales stated that she understood each of the foregoing points. She confirmed that she had already discussed the Upjohn framework with Ms. Reeves in advance of the interview and that she had no questions. Ms. Morales agreed to proceed with the interview on the terms described.

II. Background on Jenna Morales

A. Employment History

Ms. Morales's current title is Vice President of Development at Aurelius Pacific Studios Inc. ("APS"), the Los Angeles–based film and streaming content subsidiary of Aurelius Global Media Group PLC ("AGMG"). Ms. Morales has been employed by APS since March 2020, a period of approximately three years at the time of the interview.

Ms. Morales reports directly to Marcus Hale, President of Aurelius Pacific Studios Inc. Her primary responsibilities include overseeing the film and streaming content development pipeline at APS, managing a team of creative executives at the director and senior director level, evaluating scripts and intellectual property acquisitions, and working directly with producers, talent representatives, and other creative stakeholders. Ms. Morales described her role as encompassing both the creative evaluation of prospective projects and the strategic alignment of APS's development slate with the company's broader content strategy as defined by AGMG leadership and the APS President's office.

Ms. Morales is based at APS headquarters, located at 3200 West Alameda Avenue, Suite 400, Burbank, California 91505. She stated that she works from the office approximately four days per week and occasionally works remotely or travels for production-related business.

Prior to joining APS, Ms. Morales held development executive positions at two other major entertainment companies, the details of which were not explored in depth during the interview, as they were not directly relevant to the matters under investigation.

B. Reporting Relationship with Marcus Hale

Ms. Morales confirmed that she is a direct report to Marcus Hale, President of APS. She explained that while Hale oversees a broader leadership team of approximately nine Senior Vice Presidents across various divisions of the studio, he also directly supervises certain Vice President–level executives in the development function, including Ms. Morales. As a result, Ms. Morales interacts with Hale on a regular and frequent basis, including through weekly one-on-one meetings, group development slate reviews, and production-related travel.

Ms. Morales stated that she initially had a positive professional relationship with Hale when she joined APS in March 2020. She described Hale as "charismatic," "energetic," and "genuinely supportive" of her career development during the first approximately two years of her employment. She noted that Hale advocated for her promotion to Vice President and provided her with opportunities to lead high-profile projects that expanded her visibility within the organization and the broader industry.

Ms. Morales stated that the nature of her relationship with Hale began to change in approximately September 2022. She described a gradual but noticeable shift in Hale's behavior from professional mentorship to what she perceived as personal and eventually sexual interest. The specific incidents giving rise to this characterization are detailed in Section III below.

C. Performance History

Ms. Morales stated that her performance reviews at APS have been consistently positive throughout her tenure. She received an "exceeds expectations" rating in both her fiscal year 2021 and fiscal year 2022 annual performance reviews. She stated that these reviews were conducted by Hale, as her direct supervisor, and that the written evaluations praised her leadership of the development team, her creative judgment, and her ability to build productive relationships with talent and producers.

Ms. Morales was promoted from Senior Director of Development to Vice President of Development in January 2022, a promotion she described as the result of approximately two years of strong performance and advocacy by Hale within the APS leadership team and with AGMG's corporate office in London.

Ms. Morales stated that she was not aware of any performance deficiencies, formal or informal complaints about her work, or negative feedback from colleagues or subordinates prior to the events described in this memorandum. She stated that the first time she experienced criticism of her work from Hale occurred in approximately March 2023, in a context she attributes to retaliation, as described more fully in Section III.C below.

III. Summary of Allegations

A. Overview

Ms. Morales alleges that Marcus Hale, President of Aurelius Pacific Studios Inc., subjected her to unwanted sexual advances, sexually explicit comments, and unwelcome physical contact over a period spanning approximately September 2022 through March 2023. Ms. Morales characterized the conduct as a pattern of escalating harassment that began with comments about her appearance, progressed to sexually suggestive text messages and invitations to Hale's hotel room during a business trip, and culminated in unwelcome physical contact at a company dinner in February 2023.

Ms. Morales further alleges that after she rejected Hale's advances and began limiting her personal interactions with him, Hale retaliated against her professionally. Specifically, she alleges that Hale removed her from a high-profile development project she had been leading, reassigning it to another executive without explanation, and that he became publicly critical of her work in group settings in a manner she had not previously experienced.

With respect to the procedural history, Ms. Morales filed an initial written complaint on April 18, 2023, through the Meridian Compliance Solutions Ethics & Compliance Hotline, a third-party reporting mechanism maintained by APS and AGMG for employee complaints. The complaint was assigned case reference number MCS-1014-00001. The complaint was initially submitted anonymously. On April 19, 2023, Ms. Morales self-identified to Victor Gallegos, Vice President of Human Resources at APS, who had received the complaint from Meridian Compliance Solutions. Mr. Gallegos escalated the complaint to Fiona Blackwood, General Counsel of AGMG, and Patricia Sung, Chief People Officer of AGMG, on the same day.

Shortly thereafter, Ms. Morales retained Sandra Reeves of Nakamura Reeves LLP as personal counsel. On April 20, 2023, Ms. Reeves sent a demand letter on behalf of Ms. Morales to Aurelius Pacific Studios Inc., directed to the attention of Victor Gallegos, VP of Human Resources. The demand letter alleged violations of the California Fair Employment and Housing Act ("FEHA"), Cal. Gov. Code §§ 12940 et seq., including claims of sexual harassment and retaliation in violation of Cal. Gov. Code § 12940(j) and § 12940(h), respectively. The demand letter further demanded the preservation of all documents, communications, and electronically stored information relevant to the allegations.

B. Specific Incidents

Ms. Morales provided a detailed account of specific incidents of alleged harassment. Each incident is summarized below in chronological order.

B.1. September 2022 — Onset of Unwelcome Conduct

Ms. Morales stated that beginning in approximately September 2022, Hale's behavior toward her shifted from professional to personal in nature. She could not identify a single precipitating event but described a gradual change in the tone and content of Hale's interactions with her over a period of several weeks.

Specifically, Hale began making comments about Ms. Morales's physical appearance during meetings and professional interactions. Ms. Morales recounted that Hale made remarks about her clothing being "flattering" on multiple occasions, including once during a development slate review meeting attended by other members of the team. She also recalled Hale commenting that she "always looked good" during a hallway conversation at APS headquarters. Ms. Morales stated that these comments were not typical of Hale's prior interactions with her and were not the type of professional feedback she was accustomed to receiving from him.

Ms. Morales stated that she initially dismissed the comments as awkward or misdirected compliments. However, the comments increased in frequency over the following weeks and became more explicitly personal in nature. She could not provide exact dates for each instance but stated that appearance-related comments occurred on at least four to five occasions during September and into October 2022.

During this same period, Hale began suggesting one-on-one dinners outside of work. Ms. Morales stated that Hale proposed dinner on at least two or three occasions in September 2022, framing the invitations as opportunities to discuss her career or development projects. Ms. Morales declined each invitation, citing other commitments such as existing plans or the need to prepare for upcoming meetings. She stated that while one-on-one meals with supervisors were not unusual in the entertainment industry, the context of Hale's invitations — combined with his escalating comments about her appearance — caused her to feel uncomfortable and to suspect that his intentions were personal rather than professional.

B.2. October 2022 — Vancouver Production Trip

Ms. Morales traveled to Vancouver, British Columbia, in October 2022 in connection with a production trip related to an APS streaming project then in principal photography. Hale was also present on the trip in his capacity as President of APS, overseeing the production alongside the producing team. The trip lasted approximately four to five days, during which the APS group stayed at a hotel in downtown Vancouver.

Ms. Morales described two specific incidents during the Vancouver trip in which Hale invited her to his hotel room:

First invitation: Ms. Morales stated that on the first or second evening of the trip, after a group dinner at a restaurant near the hotel attended by approximately eight to ten APS and production personnel, Hale approached her in the hotel lobby as the group was dispersing. He asked her to come up to his suite to review dailies from the production and discuss strategy for the project. Ms. Morales stated that she declined, telling Hale that she was tired and planned to turn in for the evening. She noted that reviewing dailies in a hotel suite at that hour was not a standard practice and that there were appropriate production facilities on set for such reviews during business hours.

Second invitation: The following evening, at approximately 10:30 p.m., Hale sent Ms. Morales a text message asking her to come to his hotel room. Ms. Morales recalled that the message stated, in substance, that he had a bottle of wine and wanted to "talk about her career trajectory." Ms. Morales again declined via text message, stating that she had an early call time the next morning. She did not engage in further text message exchanges with Hale that evening.

Ms. Morales stated that the context, timing, and private setting of these invitations made it clear to her that they were personal in nature and not legitimate professional requests. She emphasized that the late hour, the suggestion of alcohol, and the use of pretextual professional topics (dailies review, career discussion) were, in her assessment, designed to lure her to a private setting. Ms. Morales stated that she felt uncomfortable and anxious for the remainder of the trip. She described being conscious of Hale's presence and intentionally avoiding being alone with him for the balance of their time in Vancouver.

B.3. November–December 2022 — Sexually Suggestive Text Messages

Ms. Morales described receiving three text messages from Hale during November and December 2022 that she characterized as sexually suggestive and unwelcome. She described each message individually:

November 14, 2022: Hale sent Ms. Morales a text message commenting on a photograph she had posted on a personal social media account (Ms. Morales identified the platform as Northpoint Services Inc.). The message stated words to the effect that she looked "incredibly sexy" in the photograph and asked "who's the lucky guy?" Ms. Morales stated that the photograph depicted her at a social event with friends and was not provocative or otherwise unusual. She stated that she was surprised and uncomfortable that Hale was monitoring her personal social media posts and that his use of the word "sexy" crossed a clear professional boundary. Ms. Morales responded to the message with a brief "thanks" but did not engage further. She stated that in retrospect she wished she had not responded at all, but that at the time she felt pressured to be polite to her direct supervisor.

November 29, 2022: Hale sent Ms. Morales a text message late in the evening — Ms. Morales recalled the time as approximately 10:00 p.m. or later — stating that he was "thinking about her" and that he wished they could "spend more time together outside the office." Ms. Morales stated that this message was unambiguously personal and that the phrase "thinking about you" late at night carried a clear romantic or sexual connotation. She did not respond to the message.

December 8, 2022: Following an APS company holiday party held at a venue in Burbank (Ms. Morales recalled it may have been at The Castaway or a similar location), Hale sent Ms. Morales a text message referencing the dress she had worn to the event that evening. Ms. Morales stated that the message contained a comment she characterized as "explicitly sexual in nature." When asked to elaborate, Ms. Morales stated that she did not wish to quote the message verbatim during the interview but paraphrased its content as a comment that referenced her body in a sexualized manner. She confirmed that the message went beyond commenting on her attire and made a reference to what she described as a physical or sexual attribute. Ms. Morales did not respond to this message.

Ms. Morales stated that she preserved screenshots of all three text messages on her personal phone. She indicated that she had provided copies of the screenshots to her counsel, Sandra Reeves, and that the screenshots would be produced to the investigation team through Ms. Reeves's office. The investigation team confirmed that it would follow up with Nakamura Reeves LLP to obtain the screenshots pursuant to the agreed-upon production protocol.

It was noted during the interview that Linden Forensics Group Inc. completed a forensic collection of electronic data from Hale's company-issued devices and, to the extent accessible, personal devices during the period of May 10–12, 2023. The investigation team will cross-reference recovered text messages and other communications from the Linden collection against Ms. Morales's account and the screenshots she has preserved. This cross-referencing effort is part of the ongoing document review that commenced on May 15, 2023.

B.4. January 11, 2023 — One-on-One Meeting Comment

Ms. Morales described an incident that occurred during a scheduled one-on-one meeting with Hale in his office at APS headquarters in Burbank on January 11, 2023. The meeting was one of Ms. Morales's regularly scheduled weekly meetings with Hale, at which they typically reviewed the status of projects in development, upcoming pitch meetings, and other operational matters.

Ms. Morales stated that during a discussion about an upcoming development slate presentation that she was preparing for a senior leadership review, Hale made a comment about her physical appearance that she found deeply inappropriate. Specifically, Ms. Morales recounted that Hale said words to the effect of: "You know, you're the most attractive woman in this building, and it's distracting." Ms. Morales acknowledged some uncertainty about the precise wording but stated she was confident in the substance and import of the remark.

Ms. Morales stated that she was taken aback by the comment and attempted to redirect the conversation to business matters. She recalled saying something to the effect of, "I appreciate that, but let's get back to the slate," or words of similar import. She stated that Hale did not pursue the comment further during that meeting but responded to her redirection with a smile that Ms. Morales described as "knowing" or "suggestive," as though he was communicating that both of them understood the subtext of his remark.

No other individuals were present in Hale's office during this meeting. Ms. Morales stated that the comment occurred during a segment of the meeting when the door to Hale's office was closed.

Ms. Morales stated that she made a contemporaneous note about this incident in a personal journal application on her phone. She identified the entry as having been made on or about January 11, 2023, either on the same day as the incident or the day following. She offered to provide the journal entry to the investigation team through her counsel. The investigation team confirmed that it would request production of the journal entry through Nakamura Reeves LLP.

B.5. February 3, 2023 — Company Dinner / Physical Contact

Ms. Morales described an incident of unwelcome physical contact that occurred at a company dinner on February 3, 2023. She identified the event as a team dinner attended by approximately twelve to fifteen APS executives, held at a restaurant in Burbank. Ms. Morales could not recall the precise name of the restaurant at the time of the interview but described it as an Italian restaurant that APS had used for team events on prior occasions.

During the dinner, Hale was seated next to Ms. Morales. Ms. Morales stated that she did not select the seating arrangement and was uncertain whether it was coincidental or intentional.

Ms. Morales described three instances of unwelcome physical contact by Hale during the dinner:

First instance: At a point during the dinner when Ms. Morales stood up from her chair, Hale placed his hand on her lower back. Ms. Morales described the contact as lingering and deliberate, not the kind of incidental or brief contact that might occur in a crowded restaurant setting. She estimated that his hand remained on her lower back for several seconds.

Second instance: When Ms. Morales sat back down at the table, Hale again placed his hand on her lower back as she was settling into her seat. Again, she described the contact as deliberate and not incidental.

Third instance: Later in the evening, while both were seated at the table, Hale placed his hand on Ms. Morales's thigh under the table. Ms. Morales stated that the contact occurred without any prior physical gesture or conversational cue and was entirely unwelcome. She estimated that the contact lasted approximately five to ten seconds before she shifted in her seat, at which point Hale removed his hand. Ms. Morales stated that she did not verbally confront Hale about the contact at the time but was visibly uncomfortable.

Ms. Morales stated that she left the dinner early, telling colleagues that she had a headache. She stated that this was not true and that her actual reason for leaving was her discomfort with Hale's physical conduct. She stated that she went directly home and felt upset and shaken by the experience.

Ms. Morales identified at least two colleagues who were seated nearby at the dinner and who, in her assessment, may have observed Hale's behavior. She provided their names during the interview. These names have been recorded separately and will be cross-referenced with the corroborating witness list that has been compiled in connection with the investigation. As discussed elsewhere in this memorandum, a total of seven corroborating witnesses were ultimately identified over the course of the investigation.

Ms. Morales stated that the February 3, 2023 dinner incident was the "tipping point" that led her to begin seriously considering filing a formal complaint. She described the physical contact as a significant escalation beyond the prior verbal comments and text messages and stated that it made her feel that the situation had become untenable and that Hale would not stop his behavior without external intervention.

Ms. Morales stated that she made a contemporaneous journal entry about the dinner incident on the evening of February 3, 2023 or the following day. As noted above, she offered to produce the journal entry through her counsel.

C. Alleged Retaliation

Ms. Morales stated that following the February 3, 2023 dinner incident, she began deliberately distancing herself from Hale in professional settings. Specifically, she declined non-essential one-on-one meetings with Hale, instead communicating primarily by email, and she arranged for other members of her team to attend meetings with Hale in her place when feasible. She stated that she continued to fulfill her job responsibilities but sought to minimize direct personal interaction with Hale.

Ms. Morales stated that in approximately late February or early March 2023 — she could not recall the precise date — Hale removed her from a high-profile development project that she had been leading for several months. The project, which Ms. Morales described as a significant franchise property that was a priority for the studio, was reassigned to another executive at the SVP level. Ms. Morales stated that Hale did not provide her with an explanation for the reassignment. She learned about it when another member of the development team informed her that the project had been reassigned, and Hale subsequently confirmed the change in a brief email that offered no substantive rationale.

Ms. Morales further stated that during approximately the same period, in March 2023, Hale became noticeably colder and more critical of her work in group settings. She described instances in which Hale made disparaging comments about her team's development choices in front of colleagues during slate review meetings, questioning her creative judgment in ways he had never done before. She stated that these comments stood in stark contrast to the consistently positive performance evaluations she had received and to Hale's prior vocal support for her work.

Ms. Morales stated that she believed these actions — the removal from the project and the public criticism — were retaliatory in nature. She characterized them as a direct consequence of her rejection of Hale's sexual advances, her refusal to engage with his personal overtures, and her withdrawal from personal interaction with him. She noted that the timing was, in her view, unmistakable: the professional consequences began shortly after she distanced herself following the dinner incident.

Ms. Morales stated that she discussed the situation with one or two trusted colleagues in approximately March and early April 2023, prior to filing her formal complaint. She stated that these conversations reinforced her belief that Hale's behavior constituted harassment and retaliation and encouraged her to pursue a formal complaint. She ultimately submitted her hotline complaint on April 18, 2023, as described in Section IV below.

IV. Filing of Formal Complaint

Ms. Morales described the process by which she filed her formal complaint in detail:

On April 18, 2023, Ms. Morales submitted a written complaint through the Meridian Compliance Solutions Ethics & Compliance Hotline, a third-party reporting mechanism maintained by APS and AGMG for the confidential submission of employee complaints regarding potential violations of company policy, including harassment and retaliation. The complaint was assigned case reference number MCS-1014-00001 by the Meridian system.

Ms. Morales stated that she chose the Meridian hotline because it offered the ability to submit a complaint anonymously as an initial step. She stated that she was concerned about potential retaliation from Hale and wanted to ensure that her complaint was documented before she identified herself. The complaint was therefore initially submitted anonymously.

On April 19, 2023, Ms. Morales self-identified to Victor Gallegos, Vice President of Human Resources at APS. Mr. Gallegos had received the anonymous complaint from Meridian Compliance Solutions on or about the same date. Upon Ms. Morales's self-identification, Mr. Gallegos escalated the complaint to Fiona Blackwood, General Counsel of Aurelius Global Media Group PLC, and Patricia Sung, Chief People Officer of AGMG, on the same day, April 19, 2023.

Shortly after self-identifying, Ms. Morales retained Sandra Reeves of Nakamura Reeves LLP as her personal attorney. On April 20, 2023, Ms. Reeves sent a formal demand letter on Ms. Morales's behalf to Aurelius Pacific Studios Inc., directed to the attention of Victor Gallegos. The demand letter alleged violations of the California Fair Employment and Housing Act (FEHA), including claims of sexual harassment in violation of Cal. Gov. Code § 12940(j) and retaliation in violation of Cal. Gov. Code § 12940(h). The demand letter further demanded the immediate preservation of all documents, communications, electronically stored information, and other materials relevant to the allegations set forth therein.

Ms. Morales stated that she was aware that Claire Ngo, Senior Director of Talent Relations at APS, had filed a separate complaint corroborating aspects of Ms. Morales's account on April 24, 2023. Ms. Morales emphasized, however, that she did not coordinate with Ms. Ngo in advance of filing her own complaint. She stated that she and Ms. Ngo discussed the situation only after Ms. Morales had already submitted her hotline complaint, and that Ms. Ngo's decision to file a corroborating complaint was made independently. The nature and content of Ms. Ngo's complaint will be addressed in a separate interview memorandum following her scheduled interview on May 25, 2023.

V. Morales's Knowledge of Other Complaints or Concerns

Ms. Morales was asked whether she was aware of any other complaints, concerns, or incidents involving Marcus Hale and other employees, either at APS or elsewhere within the AGMG organization.

Ms. Morales stated that she was aware of "rumors" circulating among female employees at APS that Hale had behaved inappropriately toward other women in the past. She described these rumors as a general awareness within the organization that Hale's conduct toward women could be unprofessional, but she stated that she did not have direct knowledge of specific prior incidents or formal complaints.

Ms. Morales stated that she had heard informally — through conversations with colleagues whose names she did not disclose during this portion of the interview — that a former executive assistant to Hale had left the company under circumstances that some colleagues attributed to Hale's behavior. Ms. Morales could not identify the former executive assistant by name but described her understanding as follows: the individual had worked closely with Hale, had experienced some form of inappropriate conduct, and had departed APS rather than pursue a formal complaint. Ms. Morales emphasized that her knowledge of this matter was entirely secondhand.

Investigator's note: This account appears to reference Serena Whitcomb, former Executive Assistant to Marcus Hale, who was employed at APS from approximately April 2019 through September 2021 and who made an informal complaint regarding Hale's conduct in July 2021. This connection will be explored and confirmed during Ms. Whitcomb's own interview, which is to be scheduled as part of the investigation.

Ms. Morales also stated that she was aware that Darren Whitfield, Senior Vice President of Physical Production at APS, had expressed concerns about Hale's treatment of women within the organization. Specifically, Ms. Morales stated that she had heard from colleagues that Whitfield raised concerns about Hale's behavior toward female employees during a leadership meeting on approximately January 23, 2023. Ms. Morales was not present at this meeting and could not provide details about what Whitfield said or how his comments were received. She stated only that she learned about Whitfield's remarks secondhand. Mr. Whitfield is scheduled for an interview on May 30, 2023, at which time his account of the January 23 meeting will be explored.

VI. Impact on Morales

Ms. Morales described the significant personal and professional impact of Hale's conduct on her well-being.

From an emotional standpoint, Ms. Morales stated that she has experienced substantial distress as a result of the harassment, including persistent anxiety, difficulty sleeping, and a general reluctance to attend work events, particularly those at which Hale might be present. She described feeling hypervigilant in professional settings, constantly aware of Hale's proximity and behavior, which she stated has been mentally exhausting and has interfered with her ability to focus on her work.

Ms. Morales stated that she considered resigning from APS on multiple occasions during the period from February through April 2023. Ultimately, she decided against resigning because she felt it would be fundamentally unfair to abandon a career she had spent years building because of Hale's misconduct. She stated that her decision to file a formal complaint was motivated in part by her desire to remain at the company and to ensure that the behavior was addressed so that she — and other women at APS — could work in a safe and professional environment.

Ms. Morales stated that she began seeing a licensed therapist in approximately January 2023 to address the stress and anxiety caused by Hale's behavior. She stated that she continues to attend therapy sessions on a regular basis. She did not provide the name of her therapist during the interview, and the investigation team did not request this information, consistent with the scope of the current inquiry.

Ms. Morales expressed ongoing concern about potential retaliation in connection with the investigation, notwithstanding the fact that Hale was placed on paid administrative leave effective May 3, 2023. She stated that she is worried about the possibility of indirect retaliation by individuals aligned with Hale within the organization, including potential damage to her professional reputation. She requested that Calderwood & Harkness and the company take steps to ensure that she is protected from any form of retaliation during and after the investigation.

VII. Documentary Evidence Referenced

During the interview, Ms. Morales referenced the following categories of documentary evidence relevant to her allegations:

1. Text message screenshots (3): Screenshots of three text messages sent by Marcus Hale to Ms. Morales, dated November 14, 2022, November 29, 2022, and December 8, 2022, respectively. These screenshots are preserved on Ms. Morales's personal phone. Ms. Morales stated that copies have been provided to her counsel, Sandra Reeves of Nakamura Reeves LLP, and will be produced to the investigation team through Ms. Reeves's office pursuant to the agreed-upon production protocol.

2. Contemporaneous journal entries: Ms. Morales stated that she maintained contemporaneous notes in a personal journal application on her phone regarding at least two incidents: the January 11, 2023 one-on-one meeting comment and the February 3, 2023 company dinner incident. She offered to produce these entries to the investigation team through her counsel.

3. Written hotline complaint: Ms. Morales's written complaint submitted on April 18, 2023, through the Meridian Compliance Solutions Ethics & Compliance Hotline, assigned case reference number MCS-1014-00001. A copy of this complaint was received by the investigation team from Victor Gallegos, VP of Human Resources at APS.

4. Demand letter from Sandra Reeves: The formal demand letter dated April 20, 2023, sent by Sandra Reeves of Nakamura Reeves LLP on behalf of Ms. Morales to Aurelius Pacific Studios Inc., alleging FEHA violations and demanding document preservation. A copy of this letter was received by the investigation team from Fiona Blackwood, General Counsel of AGMG.

5. Forensic collection data (Linden Forensics Group Inc.): Linden Forensics Group Inc. completed a forensic collection of electronic data from Hale's company-issued and, to the extent accessible, personal devices, as well as Ms. Morales's company-issued devices, during the collection period of May 10–12, 2023. The cross-referencing of Ms. Morales's account of text messages and other communications against the data recovered in the Linden collection is currently ongoing as part of the document review, which commenced on May 15, 2023. The filtered document review set encompasses approximately 38,600 items as of the date of this memorandum.

VIII. Morales's Awareness of Applicable Policies

Ms. Morales was asked about her familiarity with APS's policies regarding harassment, discrimination, and retaliation, as well as the formal complaint procedures available to employees.

Ms. Morales stated that she was familiar with the APS Employee Handbook (California Supplement), which was most recently revised on March 15, 2022. She specifically identified her awareness of the following provisions:

• Section 5.3 — Anti-Harassment & Anti-Discrimination Policy: Ms. Morales stated that she was aware of the company's prohibition against harassment and discrimination on the basis of sex, gender, and other protected characteristics. She stated that she understood the policy to cover the type of conduct she experienced.

• Section 5.7 — Anti-Retaliation Policy: Ms. Morales stated that she was aware of the company's policy prohibiting retaliation against employees who report concerns about harassment or discrimination in good faith.

• Section 8.1 — Formal Complaint Procedures: Ms. Morales stated she was familiar with the formal complaint procedures outlined in the handbook, including the availability of the Meridian Compliance Solutions hotline and the option to report concerns to Human Resources or the General Counsel's office.

Ms. Morales stated that she attended annual harassment prevention training as required by California law (Cal. Gov. Code § 12950.1). She recalled attending training sessions in 2021 and 2022 and stated that the training addressed the definition of harassment, the complaint procedures available to employees, and the company's anti-retaliation protections.

Ms. Morales explained that she initially chose not to use the formal complaint procedures set forth in Section 8.1 of the handbook for several reasons. First, she feared retaliation from Hale, who, as the President of APS, was the most senior executive at the US studio division and reported only to Elliot Vane, the CEO of AGMG, based in London. Ms. Morales stated that she did not believe that any individual within the APS organization could effectively address a complaint against its own president without risk to the complainant. Second, she was uncertain about whether the internal process would be conducted fairly or confidentially, given Hale's position and influence within the company.

Ms. Morales stated that she ultimately decided to file her complaint through the Meridian Compliance Solutions hotline because it offered the ability to submit an anonymous complaint as an initial step, which she viewed as a way to document her concerns while minimizing her immediate exposure to potential retaliation. She stated that the availability of anonymity was a decisive factor in her decision to come forward when she did.

IX. Demeanor and Credibility Observations

The following observations regarding Ms. Morales's demeanor and credibility are noted for the investigation file:

Ms. Morales was composed and articulate throughout the approximately three-hour-and-forty-five-minute interview. She answered questions directly and without evasion, and she demonstrated a clear understanding of the distinction between the information sought and the scope of her personal knowledge. She was cooperative and forthcoming in her responses.

Ms. Morales became visibly emotional at two points during the interview: first, when describing the February 3, 2023 dinner incident and the physical contact by Hale, and second, when discussing the broader impact of Hale's conduct on her professional confidence and emotional well-being. On both occasions, the interview was briefly paused to allow Ms. Morales to compose herself before continuing. Her emotional reactions appeared genuine and proportionate to the subject matter being discussed.

Ms. Morales's account was detailed and internally consistent throughout the interview. She provided specific dates, locations, and contextual details for each incident she described. When multiple incidents were discussed in rapid sequence, she was careful to distinguish the circumstances of each and did not conflate events or timelines.

Notably, Ms. Morales drew clear distinctions between what she directly experienced, what she personally observed, and what she learned from others. For example, she was careful to note that her knowledge of the former executive assistant's departure and of Darren Whitfield's comments at the January 23 leadership meeting was based on secondhand information rather than direct observation.

Ms. Morales acknowledged areas of uncertainty where appropriate. She stated that she could not recall the exact wording of certain comments made by Hale (e.g., the January 11 meeting comment) and that she could not recall the precise name of the restaurant where the February 3 dinner took place. She did not attempt to fill these gaps with speculation or embellishment.

Preliminary assessment: Based on the interview, Ms. Morales presented as a credible witness. Her account was internally consistent, appropriately detailed, and supported by references to contemporaneous documentation (text message screenshots, journal entries, and the formal hotline complaint). Her account is subject to corroboration through the ongoing documentary evidence review and through the interviews of other witnesses. Over the course of the investigation, a total of seven corroborating witnesses were ultimately identified whose testimony may bear on the incidents described by Ms. Morales and the broader pattern of conduct alleged against Hale.

This preliminary credibility assessment is offered for the purpose of organizing the investigation's next steps and is subject to revision as additional evidence is gathered and analyzed.

X. Follow-Up Items

The following action items were identified based on the interview with Ms. Morales:

1. Text message screenshots: Obtain copies of the three text message screenshots (dated November 14, November 29, and December 8, 2022) from Ms. Morales through Sandra Reeves / Nakamura Reeves LLP, pursuant to the agreed-upon production protocol.

2. Journal entries: Obtain copies of the contemporaneous journal entries referenced by Ms. Morales (relating to the January 11, 2023 meeting comment and the February 3, 2023 dinner incident) through her counsel.

3. Forensic cross-referencing: Cross-reference Ms. Morales's account of text messages sent by Hale with data collected by Linden Forensics Group Inc. from Hale's company-issued and personal devices during the May 10–12, 2023 collection period.

4. Corroborating witness interviews — February 3 dinner attendees: Interview the colleagues identified by Ms. Morales as having been seated nearby during the February 3, 2023 dinner incident, as well as any additional individuals with knowledge of the events described by Ms. Morales.

5. Interview of Claire Ngo: Interview Claire Ngo, Senior Director of Talent Relations at APS, regarding her separate but corroborating complaint filed on April 24, 2023. Interview currently scheduled for May 25, 2023.

6. Interview of Darren Whitfield: Interview Darren Whitfield, Senior Vice President of Physical Production at APS, regarding his reported concerns about Hale's treatment of women, including his comments at the January 23, 2023 leadership meeting. Interview currently scheduled for May 30, 2023.

7. Interview of Victor Gallegos: Interview Victor Gallegos, Vice President of Human Resources at APS, regarding his receipt and escalation of the hotline complaint (MCS-1014-00001), the handling of any prior complaints or concerns involving Hale, and APS's compliance with its own internal complaint procedures. Interview currently scheduled for June 1, 2023.

8. Interview of Marcus Hale: Schedule and conduct an interview of Marcus Hale, President of APS, currently on paid administrative leave. The interview is to be scheduled following negotiation of terms and logistics with Hale's personal counsel, Graham Thornfield of Thornfield & Associates LLP. Calderwood & Harkness's initial outreach letter to Mr. Thornfield was sent on May 19, 2023, and a response is pending as of the date of this memorandum.

9. APS Employee Handbook review: Review Sections 5.3 (Anti-Harassment & Anti-Discrimination Policy), 5.7 (Anti-Retaliation Policy), and 8.1 (Formal Complaint Procedures) of the APS Employee Handbook (California Supplement, revised March 15, 2022) for purposes of the compliance analysis component of the investigation.

10. Ongoing document review: Continue the review of the filtered document set (approximately 38,600 items as of May 15, 2023) for evidence corroborating or contradicting the allegations made by Ms. Morales and any other complainants or witnesses.

XI. Document Retention

This memorandum constitutes privileged attorney work product prepared at the direction of counsel in connection with the independent workplace investigation authorized by the People & Culture Committee and the Audit & Risk Committee of the Board of Directors of Aurelius Global Media Group PLC. It reflects the mental impressions, conclusions, opinions, and legal theories of the attorneys involved and is prepared in anticipation of potential litigation.

This memorandum is filed in the investigation file under Matter No. 1017-00005 and is maintained by Calderwood & Harkness LLP in accordance with the firm's document retention policies and the instructions of the Board committees that authorized the investigation.

This memorandum should not be distributed, copied, or disclosed to any individual or entity without the prior written authorization of Calderwood & Harkness LLP.

Prepared by:

________________________________________

Devon Archer Lead Associate Calderwood & Harkness LLP

Date: May 22, 2023

________________________________________

Nadia Petrov Associate Calderwood & Harkness LLP

Date: May 22, 2023

Reviewed by:

________________________________________

Bernard Crawford Responsible Partner Calderwood & Harkness LLP

Date: May 22, 2023

PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT — PREPARED AT THE DIRECTION OF COUNSEL. Do Not Distribute or Copy Without Prior Authorization of Calderwood & Harkness LLP.

PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT PREPARED AT THE DIRECTION OF COUNSEL
Do Not Distribute or Copy Without Prior Authorization of Calderwood & Harkness LLP. This memorandum was prepared in anticipation of litigation and at the direction of counsel. It is protected from disclosure by the attorney-client privilege, the work product doctrine, and all other applicable privileges. Any unauthorized review, use, disclosure, or distribution of this document is strictly prohibited.
MEMORANDUM
TO: Investigation File — Matter No. 1017-00005
FROM: Devon Archer, Lead Associate, and Nadia Petrov, Associate, Calderwood & Harkness LLP
DATE: May 22, 2023
RE: Privileged Interview Summary — Jenna Morales, Vice President of Development, Aurelius Pacific Studios Inc.
SUBJECT: Independent Workplace Investigation — Allegations Against Marcus Hale, President, Aurelius Pacific Studios Inc.
I. Interview Details
A. Date, Time, and Location
The interview of Jenna Morales was conducted on May 22, 2023, which constituted the first day of witness interviews in the independent investigation authorized by the People & Culture Committee and the Audit & Risk Committee of the Board of Directors of Aurelius Global Media Group PLC ("AGMG"). The interview took place at the Los Angeles office of Calderwood & Harkness LLP, located at 1999 Avenue of the Stars, Suite 2800, Los Angeles, California 90067. A conference room on the twenty-eighth floor was reserved for the interview to ensure privacy and confidentiality.
The interview commenced at approximately 10:00 a.m. Pacific Time and concluded at approximately 1:45 p.m. Pacific Time, for a total duration of approximately three hours and forty-five minutes. This included a short break of approximately fifteen minutes, taken at approximately 11:50 a.m. at the request of the interviewee. During the break, no substantive matters were discussed. Light refreshments were available throughout the session.
B. Attendees
The following individuals were present for the interview:
•  Jenna Morales, Vice President of Development, Aurelius Pacific Studios Inc. ("APS") — interviewee
•  Devon Archer, Lead Associate, Calderwood & Harkness LLP — primary interviewer
•  Nadia Petrov, Associate, Calderwood & Harkness LLP — note-taker and secondary interviewer
No other individuals were present in the interview room at any point during the session. The interview was not audio- or video-recorded, consistent with the firm's standard practice for internal investigation witness interviews.
C. Counsel Notification
Sandra Reeves, Partner at Nakamura Reeves LLP, 515 South Flower Street, Suite 3600, Los Angeles, California 90071, is outside counsel retained by Ms. Morales in connection with the matters under investigation. Ms. Reeves was notified of the interview in advance pursuant to Calderwood & Harkness's letter to Nakamura Reeves LLP dated May 10, 2023, which set forth the date, time, location, and general scope of the interview, as well as the applicable privilege framework and the Upjohn admonition that would be administered.
Ms. Reeves elected not to attend the interview. In a written response dated May 12, 2023, Ms. Reeves confirmed Ms. Morales's willingness to participate in the interview voluntarily and requested that any follow-up questions or requests for additional information be directed through her office rather than directly to Ms. Morales. Calderwood & Harkness agreed to this protocol. At the outset of the interview, Ms. Morales confirmed verbally that she was participating voluntarily and that she understood Ms. Reeves had chosen not to attend.
D. Upjohn Admonition
At the outset of the interview, and before any substantive questions were posed, Devon Archer administered the standard Upjohn / corporate counsel admonition consistent with Calderwood & Harkness's template script used in internal investigations. The admonition was delivered orally, and Ms. Morales was afforded the opportunity to ask questions before proceeding.
Specifically, Ms. Morales was advised of the following:
(1) Calderwood & Harkness LLP represents Aurelius Global Media Group PLC and its Board of Directors in connection with this investigation. Calderwood & Harkness does not represent Ms. Morales individually, and no attorney-client relationship exists between Calderwood & Harkness and Ms. Morales.
(2) The interview and the communications taking place during the interview are protected by the attorney-client privilege, which belongs solely to the company (AGMG and its Board of Directors). The privilege does not belong to Ms. Morales.
(3) The company may choose to waive or not to waive the attorney-client privilege at its sole discretion, including by disclosing the contents of this interview to third parties, government regulators, or in the context of litigation, without Ms. Morales's consent.
(4) Ms. Morales should keep the substance of the interview confidential and should not discuss the interview or the content of her statements with coworkers, other employees of APS or AGMG, or any other individuals, other than her personal counsel, Sandra Reeves.
Ms. Morales stated that she understood each of the foregoing points. She confirmed that she had already discussed the Upjohn framework with Ms. Reeves in advance of the interview and that she had no questions. Ms. Morales agreed to proceed with the interview on the terms described.
II. Background on Jenna Morales
A. Employment History
Ms. Morales's current title is Vice President of Development at Aurelius Pacific Studios Inc. ("APS"), the Los Angeles–based film and streaming content subsidiary of Aurelius Global Media Group PLC ("AGMG"). Ms. Morales has been employed by APS since March 2020, a period of approximately three years at the time of the interview.
Ms. Morales reports directly to Marcus Hale, President of Aurelius Pacific Studios Inc. Her primary responsibilities include overseeing the film and streaming content development pipeline at APS, managing a team of creative executives at the director and senior director level, evaluating scripts and intellectual property acquisitions, and working directly with producers, talent representatives, and other creative stakeholders. Ms. Morales described her role as encompassing both the creative evaluation of prospective projects and the strategic alignment of APS's development slate with the company's broader content strategy as defined by AGMG leadership and the APS President's office.
Ms. Morales is based at APS headquarters, located at 3200 West Alameda Avenue, Suite 400, Burbank, California 91505. She stated that she works from the office approximately four days per week and occasionally works remotely or travels for production-related business.
Prior to joining APS, Ms. Morales held development executive positions at two other major entertainment companies, the details of which were not explored in depth during the interview, as they were not directly relevant to the matters under investigation.
B. Reporting Relationship with Marcus Hale
Ms. Morales confirmed that she is a direct report to Marcus Hale, President of APS. She explained that while Hale oversees a broader leadership team of approximately nine Senior Vice Presidents across various divisions of the studio, he also directly supervises certain Vice President–level executives in the development function, including Ms. Morales. As a result, Ms. Morales interacts with Hale on a regular and frequent basis, including through weekly one-on-one meetings, group development slate reviews, and production-related travel.
Ms. Morales stated that she initially had a positive professional relationship with Hale when she joined APS in March 2020. She described Hale as "charismatic," "energetic," and "genuinely supportive" of her career development during the first approximately two years of her employment. She noted that Hale advocated for her promotion to Vice President and provided her with opportunities to lead high-profile projects that expanded her visibility within the organization and the broader industry.
Ms. Morales stated that the nature of her relationship with Hale began to change in approximately September 2022. She described a gradual but noticeable shift in Hale's behavior from professional mentorship to what she perceived as personal and eventually sexual interest. The specific incidents giving rise to this characterization are detailed in Section III below.
C. Performance History
Ms. Morales stated that her performance reviews at APS have been consistently positive throughout her tenure. She received an "exceeds expectations" rating in both her fiscal year 2021 and fiscal year 2022 annual performance reviews. She stated that these reviews were conducted by Hale, as her direct supervisor, and that the written evaluations praised her leadership of the development team, her creative judgment, and her ability to build productive relationships with talent and producers.
Ms. Morales was promoted from Senior Director of Development to Vice President of Development in January 2022, a promotion she described as the result of approximately two years of strong performance and advocacy by Hale within the APS leadership team and with AGMG's corporate office in London.
Ms. Morales stated that she was not aware of any performance deficiencies, formal or informal complaints about her work, or negative feedback from colleagues or subordinates prior to the events described in this memorandum. She stated that the first time she experienced criticism of her work from Hale occurred in approximately March 2023, in a context she attributes to retaliation, as described more fully in Section III.C below.
III. Summary of Allegations
A. Overview
Ms. Morales alleges that Marcus Hale, President of Aurelius Pacific Studios Inc., subjected her to unwanted sexual advances, sexually explicit comments, and unwelcome physical contact over a period spanning approximately September 2022 through March 2023. Ms. Morales characterized the conduct as a pattern of escalating harassment that began with comments about her appearance, progressed to sexually suggestive text messages and invitations to Hale's hotel room during a business trip, and culminated in unwelcome physical contact at a company dinner in February 2023.
Ms. Morales further alleges that after she rejected Hale's advances and began limiting her personal interactions with him, Hale retaliated against her professionally. Specifically, she alleges that Hale removed her from a high-profile development project she had been leading, reassigning it to another executive without explanation, and that he became publicly critical of her work in group settings in a manner she had not previously experienced.
With respect to the procedural history, Ms. Morales filed an initial written complaint on April 18, 2023, through the Meridian Compliance Solutions Ethics & Compliance Hotline, a third-party reporting mechanism maintained by APS and AGMG for employee complaints. The complaint was assigned case reference number MCS-1014-00001. The complaint was initially submitted anonymously. On April 19, 2023, Ms. Morales self-identified to Victor Gallegos, Vice President of Human Resources at APS, who had received the complaint from Meridian Compliance Solutions. Mr. Gallegos escalated the complaint to Fiona Blackwood, General Counsel of AGMG, and Patricia Sung, Chief People Officer of AGMG, on the same day.
Shortly thereafter, Ms. Morales retained Sandra Reeves of Nakamura Reeves LLP as personal counsel. On April 20, 2023, Ms. Reeves sent a demand letter on behalf of Ms. Morales to Aurelius Pacific Studios Inc., directed to the attention of Victor Gallegos, VP of Human Resources. The demand letter alleged violations of the California Fair Employment and Housing Act ("FEHA"), Cal. Gov. Code §§ 12940 et seq., including claims of sexual harassment and retaliation in violation of Cal. Gov. Code § 12940(j) and § 12940(h), respectively. The demand letter further demanded the preservation of all documents, communications, and electronically stored information relevant to the allegations.
B. Specific Incidents
Ms. Morales provided a detailed account of specific incidents of alleged harassment. Each incident is summarized below in chronological order.
B.1. September 2022 — Onset of Unwelcome Conduct
Ms. Morales stated that beginning in approximately September 2022, Hale's behavior toward her shifted from professional to personal in nature. She could not identify a single precipitating event but described a gradual change in the tone and content of Hale's interactions with her over a period of several weeks.
Specifically, Hale began making comments about Ms. Morales's physical appearance during meetings and professional interactions. Ms. Morales recounted that Hale made remarks about her clothing being "flattering" on multiple occasions, including once during a development slate review meeting attended by other members of the team. She also recalled Hale commenting that she "always looked good" during a hallway conversation at APS headquarters. Ms. Morales stated that these comments were not typical of Hale's prior interactions with her and were not the type of professional feedback she was accustomed to receiving from him.
Ms. Morales stated that she initially dismissed the comments as awkward or misdirected compliments. However, the comments increased in frequency over the following weeks and became more explicitly personal in nature. She could not provide exact dates for each instance but stated that appearance-related comments occurred on at least four to five occasions during September and into October 2022.
During this same period, Hale began suggesting one-on-one dinners outside of work. Ms. Morales stated that Hale proposed dinner on at least two or three occasions in September 2022, framing the invitations as opportunities to discuss her career or development projects. Ms. Morales declined each invitation, citing other commitments such as existing plans or the need to prepare for upcoming meetings. She stated that while one-on-one meals with supervisors were not unusual in the entertainment industry, the context of Hale's invitations — combined with his escalating comments about her appearance — caused her to feel uncomfortable and to suspect that his intentions were personal rather than professional.
B.2. October 2022 — Vancouver Production Trip
Ms. Morales traveled to Vancouver, British Columbia, in October 2022 in connection with a production trip related to an APS streaming project then in principal photography. Hale was also present on the trip in his capacity as President of APS, overseeing the production alongside the producing team. The trip lasted approximately four to five days, during which the APS group stayed at a hotel in downtown Vancouver.
Ms. Morales described two specific incidents during the Vancouver trip in which Hale invited her to his hotel room:
First invitation: Ms. Morales stated that on the first or second evening of the trip, after a group dinner at a restaurant near the hotel attended by approximately eight to ten APS and production personnel, Hale approached her in the hotel lobby as the group was dispersing. He asked her to come up to his suite to review dailies from the production and discuss strategy for the project. Ms. Morales stated that she declined, telling Hale that she was tired and planned to turn in for the evening. She noted that reviewing dailies in a hotel suite at that hour was not a standard practice and that there were appropriate production facilities on set for such reviews during business hours.
Second invitation: The following evening, at approximately 10:30 p.m., Hale sent Ms. Morales a text message asking her to come to his hotel room. Ms. Morales recalled that the message stated, in substance, that he had a bottle of wine and wanted to "talk about her career trajectory." Ms. Morales again declined via text message, stating that she had an early call time the next morning. She did not engage in further text message exchanges with Hale that evening.
Ms. Morales stated that the context, timing, and private setting of these invitations made it clear to her that they were personal in nature and not legitimate professional requests. She emphasized that the late hour, the suggestion of alcohol, and the use of pretextual professional topics (dailies review, career discussion) were, in her assessment, designed to lure her to a private setting. Ms. Morales stated that she felt uncomfortable and anxious for the remainder of the trip. She described being conscious of Hale's presence and intentionally avoiding being alone with him for the balance of their time in Vancouver.
B.3. November–December 2022 — Sexually Suggestive Text Messages
Ms. Morales described receiving three text messages from Hale during November and December 2022 that she characterized as sexually suggestive and unwelcome. She described each message individually:
November 14, 2022: Hale sent Ms. Morales a text message commenting on a photograph she had posted on a personal social media account (Ms. Morales identified the platform as Northpoint Services Inc.). The message stated words to the effect that she looked "incredibly sexy" in the photograph and asked "who's the lucky guy?" Ms. Morales stated that the photograph depicted her at a social event with friends and was not provocative or otherwise unusual. She stated that she was surprised and uncomfortable that Hale was monitoring her personal social media posts and that his use of the word "sexy" crossed a clear professional boundary. Ms. Morales responded to the message with a brief "thanks" but did not engage further. She stated that in retrospect she wished she had not responded at all, but that at the time she felt pressured to be polite to her direct supervisor.
November 29, 2022: Hale sent Ms. Morales a text message late in the evening — Ms. Morales recalled the time as approximately 10:00 p.m. or later — stating that he was "thinking about her" and that he wished they could "spend more time together outside the office." Ms. Morales stated that this message was unambiguously personal and that the phrase "thinking about you" late at night carried a clear romantic or sexual connotation. She did not respond to the message.
December 8, 2022: Following an APS company holiday party held at a venue in Burbank (Ms. Morales recalled it may have been at The Castaway or a similar location), Hale sent Ms. Morales a text message referencing the dress she had worn to the event that evening. Ms. Morales stated that the message contained a comment she characterized as "explicitly sexual in nature." When asked to elaborate, Ms. Morales stated that she did not wish to quote the message verbatim during the interview but paraphrased its content as a comment that referenced her body in a sexualized manner. She confirmed that the message went beyond commenting on her attire and made a reference to what she described as a physical or sexual attribute. Ms. Morales did not respond to this message.
Ms. Morales stated that she preserved screenshots of all three text messages on her personal phone. She indicated that she had provided copies of the screenshots to her counsel, Sandra Reeves, and that the screenshots would be produced to the investigation team through Ms. Reeves's office. The investigation team confirmed that it would follow up with Nakamura Reeves LLP to obtain the screenshots pursuant to the agreed-upon production protocol.
It was noted during the interview that Linden Forensics Group Inc. completed a forensic collection of electronic data from Hale's company-issued devices and, to the extent accessible, personal devices during the period of May 10–12, 2023. The investigation team will cross-reference recovered text messages and other communications from the Linden collection against Ms. Morales's account and the screenshots she has preserved. This cross-referencing effort is part of the ongoing document review that commenced on May 15, 2023.
B.4. January 11, 2023 — One-on-One Meeting Comment
Ms. Morales described an incident that occurred during a scheduled one-on-one meeting with Hale in his office at APS headquarters in Burbank on January 11, 2023. The meeting was one of Ms. Morales's regularly scheduled weekly meetings with Hale, at which they typically reviewed the status of projects in development, upcoming pitch meetings, and other operational matters.
Ms. Morales stated that during a discussion about an upcoming development slate presentation that she was preparing for a senior leadership review, Hale made a comment about her physical appearance that she found deeply inappropriate. Specifically, Ms. Morales recounted that Hale said words to the effect of: "You know, you're the most attractive woman in this building, and it's distracting." Ms. Morales acknowledged some uncertainty about the precise wording but stated she was confident in the substance and import of the remark.
Ms. Morales stated that she was taken aback by the comment and attempted to redirect the conversation to business matters. She recalled saying something to the effect of, "I appreciate that, but let's get back to the slate," or words of similar import. She stated that Hale did not pursue the comment further during that meeting but responded to her redirection with a smile that Ms. Morales described as "knowing" or "suggestive," as though he was communicating that both of them understood the subtext of his remark.
No other individuals were present in Hale's office during this meeting. Ms. Morales stated that the comment occurred during a segment of the meeting when the door to Hale's office was closed.
Ms. Morales stated that she made a contemporaneous note about this incident in a personal journal application on her phone. She identified the entry as having been made on or about January 11, 2023, either on the same day as the incident or the day following. She offered to provide the journal entry to the investigation team through her counsel. The investigation team confirmed that it would request production of the journal entry through Nakamura Reeves LLP.
B.5. February 3, 2023 — Company Dinner / Physical Contact
Ms. Morales described an incident of unwelcome physical contact that occurred at a company dinner on February 3, 2023. She identified the event as a team dinner attended by approximately twelve to fifteen APS executives, held at a restaurant in Burbank. Ms. Morales could not recall the precise name of the restaurant at the time of the interview but described it as an Italian restaurant that APS had used for team events on prior occasions.
During the dinner, Hale was seated next to Ms. Morales. Ms. Morales stated that she did not select the seating arrangement and was uncertain whether it was coincidental or intentional.
Ms. Morales described three instances of unwelcome physical contact by Hale during the dinner:
First instance: At a point during the dinner when Ms. Morales stood up from her chair, Hale placed his hand on her lower back. Ms. Morales described the contact as lingering and deliberate, not the kind of incidental or brief contact that might occur in a crowded restaurant setting. She estimated that his hand remained on her lower back for several seconds.
Second instance: When Ms. Morales sat back down at the table, Hale again placed his hand on her lower back as she was settling into her seat. Again, she described the contact as deliberate and not incidental.
Third instance: Later in the evening, while both were seated at the table, Hale placed his hand on Ms. Morales's thigh under the table. Ms. Morales stated that the contact occurred without any prior physical gesture or conversational cue and was entirely unwelcome. She estimated that the contact lasted approximately five to ten seconds before she shifted in her seat, at which point Hale removed his hand. Ms. Morales stated that she did not verbally confront Hale about the contact at the time but was visibly uncomfortable.
Ms. Morales stated that she left the dinner early, telling colleagues that she had a headache. She stated that this was not true and that her actual reason for leaving was her discomfort with Hale's physical conduct. She stated that she went directly home and felt upset and shaken by the experience.
Ms. Morales identified at least two colleagues who were seated nearby at the dinner and who, in her assessment, may have observed Hale's behavior. She provided their names during the interview. These names have been recorded separately and will be cross-referenced with the corroborating witness list that has been compiled in connection with the investigation. As discussed elsewhere in this memorandum, a total of seven corroborating witnesses were ultimately identified over the course of the investigation.
Ms. Morales stated that the February 3, 2023 dinner incident was the "tipping point" that led her to begin seriously considering filing a formal complaint. She described the physical contact as a significant escalation beyond the prior verbal comments and text messages and stated that it made her feel that the situation had become untenable and that Hale would not stop his behavior without external intervention.
Ms. Morales stated that she made a contemporaneous journal entry about the dinner incident on the evening of February 3, 2023 or the following day. As noted above, she offered to produce the journal entry through her counsel.
C. Alleged Retaliation
Ms. Morales stated that following the February 3, 2023 dinner incident, she began deliberately distancing herself from Hale in professional settings. Specifically, she declined non-essential one-on-one meetings with Hale, instead communicating primarily by email, and she arranged for other members of her team to attend meetings with Hale in her place when feasible. She stated that she continued to fulfill her job responsibilities but sought to minimize direct personal interaction with Hale.
Ms. Morales stated that in approximately late February or early March 2023 — she could not recall the precise date — Hale removed her from a high-profile development project that she had been leading for several months. The project, which Ms. Morales described as a significant franchise property that was a priority for the studio, was reassigned to another executive at the SVP level. Ms. Morales stated that Hale did not provide her with an explanation for the reassignment. She learned about it when another member of the development team informed her that the project had been reassigned, and Hale subsequently confirmed the change in a brief email that offered no substantive rationale.
Ms. Morales further stated that during approximately the same period, in March 2023, Hale became noticeably colder and more critical of her work in group settings. She described instances in which Hale made disparaging comments about her team's development choices in front of colleagues during slate review meetings, questioning her creative judgment in ways he had never done before. She stated that these comments stood in stark contrast to the consistently positive performance evaluations she had received and to Hale's prior vocal support for her work.
Ms. Morales stated that she believed these actions — the removal from the project and the public criticism — were retaliatory in nature. She characterized them as a direct consequence of her rejection of Hale's sexual advances, her refusal to engage with his personal overtures, and her withdrawal from personal interaction with him. She noted that the timing was, in her view, unmistakable: the professional consequences began shortly after she distanced herself following the dinner incident.
Ms. Morales stated that she discussed the situation with one or two trusted colleagues in approximately March and early April 2023, prior to filing her formal complaint. She stated that these conversations reinforced her belief that Hale's behavior constituted harassment and retaliation and encouraged her to pursue a formal complaint. She ultimately submitted her hotline complaint on April 18, 2023, as described in Section IV below.
IV. Filing of Formal Complaint
Ms. Morales described the process by which she filed her formal complaint in detail:
On April 18, 2023, Ms. Morales submitted a written complaint through the Meridian Compliance Solutions Ethics & Compliance Hotline, a third-party reporting mechanism maintained by APS and AGMG for the confidential submission of employee complaints regarding potential violations of company policy, including harassment and retaliation. The complaint was assigned case reference number MCS-1014-00001 by the Meridian system.
Ms. Morales stated that she chose the Meridian hotline because it offered the ability to submit a complaint anonymously as an initial step. She stated that she was concerned about potential retaliation from Hale and wanted to ensure that her complaint was documented before she identified herself. The complaint was therefore initially submitted anonymously.
On April 19, 2023, Ms. Morales self-identified to Victor Gallegos, Vice President of Human Resources at APS. Mr. Gallegos had received the anonymous complaint from Meridian Compliance Solutions on or about the same date. Upon Ms. Morales's self-identification, Mr. Gallegos escalated the complaint to Fiona Blackwood, General Counsel of Aurelius Global Media Group PLC, and Patricia Sung, Chief People Officer of AGMG, on the same day, April 19, 2023.
Shortly after self-identifying, Ms. Morales retained Sandra Reeves of Nakamura Reeves LLP as her personal attorney. On April 20, 2023, Ms. Reeves sent a formal demand letter on Ms. Morales's behalf to Aurelius Pacific Studios Inc., directed to the attention of Victor Gallegos. The demand letter alleged violations of the California Fair Employment and Housing Act (FEHA), including claims of sexual harassment in violation of Cal. Gov. Code § 12940(j) and retaliation in violation of Cal. Gov. Code § 12940(h). The demand letter further demanded the immediate preservation of all documents, communications, electronically stored information, and other materials relevant to the allegations set forth therein.
Ms. Morales stated that she was aware that Claire Ngo, Senior Director of Talent Relations at APS, had filed a separate complaint corroborating aspects of Ms. Morales's account on April 24, 2023. Ms. Morales emphasized, however, that she did not coordinate with Ms. Ngo in advance of filing her own complaint. She stated that she and Ms. Ngo discussed the situation only after Ms. Morales had already submitted her hotline complaint, and that Ms. Ngo's decision to file a corroborating complaint was made independently. The nature and content of Ms. Ngo's complaint will be addressed in a separate interview memorandum following her scheduled interview on May 25, 2023.
V. Morales's Knowledge of Other Complaints or Concerns
Ms. Morales was asked whether she was aware of any other complaints, concerns, or incidents involving Marcus Hale and other employees, either at APS or elsewhere within the AGMG organization.
Ms. Morales stated that she was aware of "rumors" circulating among female employees at APS that Hale had behaved inappropriately toward other women in the past. She described these rumors as a general awareness within the organization that Hale's conduct toward women could be unprofessional, but she stated that she did not have direct knowledge of specific prior incidents or formal complaints.
Ms. Morales stated that she had heard informally — through conversations with colleagues whose names she did not disclose during this portion of the interview — that a former executive assistant to Hale had left the company under circumstances that some colleagues attributed to Hale's behavior. Ms. Morales could not identify the former executive assistant by name but described her understanding as follows: the individual had worked closely with Hale, had experienced some form of inappropriate conduct, and had departed APS rather than pursue a formal complaint. Ms. Morales emphasized that her knowledge of this matter was entirely secondhand.
Investigator's note: This account appears to reference Serena Whitcomb, former Executive Assistant to Marcus Hale, who was employed at APS from approximately April 2019 through September 2021 and who made an informal complaint regarding Hale's conduct in July 2021. This connection will be explored and confirmed during Ms. Whitcomb's own interview, which is to be scheduled as part of the investigation.
Ms. Morales also stated that she was aware that Darren Whitfield, Senior Vice President of Physical Production at APS, had expressed concerns about Hale's treatment of women within the organization. Specifically, Ms. Morales stated that she had heard from colleagues that Whitfield raised concerns about Hale's behavior toward female employees during a leadership meeting on approximately January 23, 2023. Ms. Morales was not present at this meeting and could not provide details about what Whitfield said or how his comments were received. She stated only that she learned about Whitfield's remarks secondhand. Mr. Whitfield is scheduled for an interview on May 30, 2023, at which time his account of the January 23 meeting will be explored.
VI. Impact on Morales
Ms. Morales described the significant personal and professional impact of Hale's conduct on her well-being.
From an emotional standpoint, Ms. Morales stated that she has experienced substantial distress as a result of the harassment, including persistent anxiety, difficulty sleeping, and a general reluctance to attend work events, particularly those at which Hale might be present. She described feeling hypervigilant in professional settings, constantly aware of Hale's proximity and behavior, which she stated has been mentally exhausting and has interfered with her ability to focus on her work.
Ms. Morales stated that she considered resigning from APS on multiple occasions during the period from February through April 2023. Ultimately, she decided against resigning because she felt it would be fundamentally unfair to abandon a career she had spent years building because of Hale's misconduct. She stated that her decision to file a formal complaint was motivated in part by her desire to remain at the company and to ensure that the behavior was addressed so that she — and other women at APS — could work in a safe and professional environment.
Ms. Morales stated that she began seeing a licensed therapist in approximately January 2023 to address the stress and anxiety caused by Hale's behavior. She stated that she continues to attend therapy sessions on a regular basis. She did not provide the name of her therapist during the interview, and the investigation team did not request this information, consistent with the scope of the current inquiry.
Ms. Morales expressed ongoing concern about potential retaliation in connection with the investigation, notwithstanding the fact that Hale was placed on paid administrative leave effective May 3, 2023. She stated that she is worried about the possibility of indirect retaliation by individuals aligned with Hale within the organization, including potential damage to her professional reputation. She requested that Calderwood & Harkness and the company take steps to ensure that she is protected from any form of retaliation during and after the investigation.
VII. Documentary Evidence Referenced
During the interview, Ms. Morales referenced the following categories of documentary evidence relevant to her allegations:
1.  Text message screenshots (3): Screenshots of three text messages sent by Marcus Hale to Ms. Morales, dated November 14, 2022, November 29, 2022, and December 8, 2022, respectively. These screenshots are preserved on Ms. Morales's personal phone. Ms. Morales stated that copies have been provided to her counsel, Sandra Reeves of Nakamura Reeves LLP, and will be produced to the investigation team through Ms. Reeves's office pursuant to the agreed-upon production protocol.
2.  Contemporaneous journal entries: Ms. Morales stated that she maintained contemporaneous notes in a personal journal application on her phone regarding at least two incidents: the January 11, 2023 one-on-one meeting comment and the February 3, 2023 company dinner incident. She offered to produce these entries to the investigation team through her counsel.
3.  Written hotline complaint: Ms. Morales's written complaint submitted on April 18, 2023, through the Meridian Compliance Solutions Ethics & Compliance Hotline, assigned case reference number MCS-1014-00001. A copy of this complaint was received by the investigation team from Victor Gallegos, VP of Human Resources at APS.
4.  Demand letter from Sandra Reeves: The formal demand letter dated April 20, 2023, sent by Sandra Reeves of Nakamura Reeves LLP on behalf of Ms. Morales to Aurelius Pacific Studios Inc., alleging FEHA violations and demanding document preservation. A copy of this letter was received by the investigation team from Fiona Blackwood, General Counsel of AGMG.
5.  Forensic collection data (Linden Forensics Group Inc.): Linden Forensics Group Inc. completed a forensic collection of electronic data from Hale's company-issued and, to the extent accessible, personal devices, as well as Ms. Morales's company-issued devices, during the collection period of May 10–12, 2023. The cross-referencing of Ms. Morales's account of text messages and other communications against the data recovered in the Linden collection is currently ongoing as part of the document review, which commenced on May 15, 2023. The filtered document review set encompasses approximately 38,600 items as of the date of this memorandum.
VIII. Morales's Awareness of Applicable Policies
Ms. Morales was asked about her familiarity with APS's policies regarding harassment, discrimination, and retaliation, as well as the formal complaint procedures available to employees.
Ms. Morales stated that she was familiar with the APS Employee Handbook (California Supplement), which was most recently revised on March 15, 2022. She specifically identified her awareness of the following provisions:
•  Section 5.3 — Anti-Harassment & Anti-Discrimination Policy: Ms. Morales stated that she was aware of the company's prohibition against harassment and discrimination on the basis of sex, gender, and other protected characteristics. She stated that she understood the policy to cover the type of conduct she experienced.
•  Section 5.7 — Anti-Retaliation Policy: Ms. Morales stated that she was aware of the company's policy prohibiting retaliation against employees who report concerns about harassment or discrimination in good faith.
•  Section 8.1 — Formal Complaint Procedures: Ms. Morales stated she was familiar with the formal complaint procedures outlined in the handbook, including the availability of the Meridian Compliance Solutions hotline and the option to report concerns to Human Resources or the General Counsel's office.
Ms. Morales stated that she attended annual harassment prevention training as required by California law (Cal. Gov. Code § 12950.1). She recalled attending training sessions in 2021 and 2022 and stated that the training addressed the definition of harassment, the complaint procedures available to employees, and the company's anti-retaliation protections.
Ms. Morales explained that she initially chose not to use the formal complaint procedures set forth in Section 8.1 of the handbook for several reasons. First, she feared retaliation from Hale, who, as the President of APS, was the most senior executive at the US studio division and reported only to Elliot Vane, the CEO of AGMG, based in London. Ms. Morales stated that she did not believe that any individual within the APS organization could effectively address a complaint against its own president without risk to the complainant. Second, she was uncertain about whether the internal process would be conducted fairly or confidentially, given Hale's position and influence within the company.
Ms. Morales stated that she ultimately decided to file her complaint through the Meridian Compliance Solutions hotline because it offered the ability to submit an anonymous complaint as an initial step, which she viewed as a way to document her concerns while minimizing her immediate exposure to potential retaliation. She stated that the availability of anonymity was a decisive factor in her decision to come forward when she did.
IX. Demeanor and Credibility Observations
The following observations regarding Ms. Morales's demeanor and credibility are noted for the investigation file:
Ms. Morales was composed and articulate throughout the approximately three-hour-and-forty-five-minute interview. She answered questions directly and without evasion, and she demonstrated a clear understanding of the distinction between the information sought and the scope of her personal knowledge. She was cooperative and forthcoming in her responses.
Ms. Morales became visibly emotional at two points during the interview: first, when describing the February 3, 2023 dinner incident and the physical contact by Hale, and second, when discussing the broader impact of Hale's conduct on her professional confidence and emotional well-being. On both occasions, the interview was briefly paused to allow Ms. Morales to compose herself before continuing. Her emotional reactions appeared genuine and proportionate to the subject matter being discussed.
Ms. Morales's account was detailed and internally consistent throughout the interview. She provided specific dates, locations, and contextual details for each incident she described. When multiple incidents were discussed in rapid sequence, she was careful to distinguish the circumstances of each and did not conflate events or timelines.
Notably, Ms. Morales drew clear distinctions between what she directly experienced, what she personally observed, and what she learned from others. For example, she was careful to note that her knowledge of the former executive assistant's departure and of Darren Whitfield's comments at the January 23 leadership meeting was based on secondhand information rather than direct observation.
Ms. Morales acknowledged areas of uncertainty where appropriate. She stated that she could not recall the exact wording of certain comments made by Hale (e.g., the January 11 meeting comment) and that she could not recall the precise name of the restaurant where the February 3 dinner took place. She did not attempt to fill these gaps with speculation or embellishment.
Preliminary assessment: Based on the interview, Ms. Morales presented as a credible witness. Her account was internally consistent, appropriately detailed, and supported by references to contemporaneous documentation (text message screenshots, journal entries, and the formal hotline complaint). Her account is subject to corroboration through the ongoing documentary evidence review and through the interviews of other witnesses. Over the course of the investigation, a total of seven corroborating witnesses were ultimately identified whose testimony may bear on the incidents described by Ms. Morales and the broader pattern of conduct alleged against Hale.
This preliminary credibility assessment is offered for the purpose of organizing the investigation's next steps and is subject to revision as additional evidence is gathered and analyzed.
X. Follow-Up Items
The following action items were identified based on the interview with Ms. Morales:
1.  Text message screenshots: Obtain copies of the three text message screenshots (dated November 14, November 29, and December 8, 2022) from Ms. Morales through Sandra Reeves / Nakamura Reeves LLP, pursuant to the agreed-upon production protocol.
2.  Journal entries: Obtain copies of the contemporaneous journal entries referenced by Ms. Morales (relating to the January 11, 2023 meeting comment and the February 3, 2023 dinner incident) through her counsel.
3.  Forensic cross-referencing: Cross-reference Ms. Morales's account of text messages sent by Hale with data collected by Linden Forensics Group Inc. from Hale's company-issued and personal devices during the May 10–12, 2023 collection period.
4.  Corroborating witness interviews — February 3 dinner attendees: Interview the colleagues identified by Ms. Morales as having been seated nearby during the February 3, 2023 dinner incident, as well as any additional individuals with knowledge of the events described by Ms. Morales.
5.  Interview of Claire Ngo: Interview Claire Ngo, Senior Director of Talent Relations at APS, regarding her separate but corroborating complaint filed on April 24, 2023. Interview currently scheduled for May 25, 2023.
6.  Interview of Darren Whitfield: Interview Darren Whitfield, Senior Vice President of Physical Production at APS, regarding his reported concerns about Hale's treatment of women, including his comments at the January 23, 2023 leadership meeting. Interview currently scheduled for May 30, 2023.
7.  Interview of Victor Gallegos: Interview Victor Gallegos, Vice President of Human Resources at APS, regarding his receipt and escalation of the hotline complaint (MCS-1014-00001), the handling of any prior complaints or concerns involving Hale, and APS's compliance with its own internal complaint procedures. Interview currently scheduled for June 1, 2023.
8.  Interview of Marcus Hale: Schedule and conduct an interview of Marcus Hale, President of APS, currently on paid administrative leave. The interview is to be scheduled following negotiation of terms and logistics with Hale's personal counsel, Graham Thornfield of Thornfield & Associates LLP. Calderwood & Harkness's initial outreach letter to Mr. Thornfield was sent on May 19, 2023, and a response is pending as of the date of this memorandum.
9.  APS Employee Handbook review: Review Sections 5.3 (Anti-Harassment & Anti-Discrimination Policy), 5.7 (Anti-Retaliation Policy), and 8.1 (Formal Complaint Procedures) of the APS Employee Handbook (California Supplement, revised March 15, 2022) for purposes of the compliance analysis component of the investigation.
10.  Ongoing document review: Continue the review of the filtered document set (approximately 38,600 items as of May 15, 2023) for evidence corroborating or contradicting the allegations made by Ms. Morales and any other complainants or witnesses.
XI. Document Retention
This memorandum constitutes privileged attorney work product prepared at the direction of counsel in connection with the independent workplace investigation authorized by the People & Culture Committee and the Audit & Risk Committee of the Board of Directors of Aurelius Global Media Group PLC. It reflects the mental impressions, conclusions, opinions, and legal theories of the attorneys involved and is prepared in anticipation of potential litigation.
This memorandum is filed in the investigation file under Matter No. 1017-00005 and is maintained by Calderwood & Harkness LLP in accordance with the firm's document retention policies and the instructions of the Board committees that authorized the investigation.
This memorandum should not be distributed, copied, or disclosed to any individual or entity without the prior written authorization of Calderwood & Harkness LLP.
Prepared by:
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Devon Archer Lead Associate Calderwood & Harkness LLP
Date: May 22, 2023
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Nadia Petrov Associate Calderwood & Harkness LLP
Date: May 22, 2023
Reviewed by:
________________________________________
Bernard Crawford Responsible Partner Calderwood & Harkness LLP
Date: May 22, 2023
PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT — PREPARED AT THE DIRECTION OF COUNSEL. Do Not Distribute or Copy Without Prior Authorization of Calderwood & Harkness LLP.

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

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