[sheet: Interview Tracker]

[sheet: Interview Tracker]
Interview # | Witness Name | Title / Role | Organization | Witness Category | Interview Date | Interview Time | Location | Interviewer(s) | Duration | Counsel Present | Upjohn Warning Administered | Status | Notes
1 | Jenna Morales | Vice President of Development | Aurelius Pacific Studios Inc. | Complainant | 2023-05-22 | 10:00 AM | Calderwood & Harkness LLP, 1999 Avenue of the Stars, Suite 2800, Los Angeles, CA 90067 | Devon Archer; Nadia Petrov | 2:45 | Sandra Reeves (Nakamura Reeves LLP) notified; did not attend | Yes | Completed | Primary complainant. Filed initial hotline complaint (MCS-1014-00001) on April 18, 2023. Alleges unwanted sexual advances and sexually explicit comments by Hale from Sept 2022 – March 2023. Memo prepared May 22, 2023.
2 | SVP Witness A | SVP, Business Affairs | Aurelius Pacific Studios Inc. | Current Employee | 2023-05-24 | 10:00 AM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer; Nadia Petrov | 1:30 | None | Yes | Completed | One of Hale's 9 direct reports. Corroborating witness re Morales allegations. Also identified as forensic collection custodian.
3 | Claire Ngo | Senior Director of Talent Relations | Aurelius Pacific Studios Inc. | Complainant | 2023-05-25 | 1:00 PM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer; Nadia Petrov | 2:15 | None | Yes | Completed | Complainant. Filed corroborating complaint April 24, 2023. Alleges sexually suggestive comments at Monarch Valley Resort off-site (Ojai, CA) Feb 17–18, 2023 and subsequent exclusion from strategy meetings March–April 2023. Memo prepared May 25, 2023.
4 | SVP Witness B | SVP, Marketing & Distribution | Aurelius Pacific Studios Inc. | Current Employee | 2023-05-26 | 2:00 PM | Calderwood & Harkness LLP, Los Angeles office | Nadia Petrov | 1:15 | None | Yes | Completed | One of Hale's direct reports. Corroborating witness re Morales allegations. Also identified as forensic collection custodian.
5 | Darren Whitfield | SVP of Physical Production | Aurelius Pacific Studios Inc. | Complainant | 2023-05-30 | 10:00 AM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer | 2:30 | None | Yes | Completed | Complainant (retaliation). Voluntarily reported concerns April 26, 2023. Raised concerns re Hale's conduct toward female employees at Jan 23, 2023 leadership meeting. Project Meridian and Project Halcyon ($187M combined budget) reassigned from Whitfield to Cameron Briggs on Feb 6, 2023. Memo prepared May 30, 2023.
6 | Victor Gallegos | VP of Human Resources | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-01 | 9:30 AM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer; Nadia Petrov | 3:00 | None | Yes | Completed | Received initial hotline complaint from Meridian Compliance Solutions; escalated to Fiona Blackwood and Patricia Sung on April 19, 2023. Confirmed prior informal complaint by Serena Whitcomb (July 2021); verbal counseling issued to Hale on Aug 2, 2021 with no written documentation retained. Memo prepared June 1, 2023.
7 | SVP Witness C | SVP, Streaming Content | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-02 | 10:00 AM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer | 1:20 | None | Yes | Completed | One of Hale's direct reports. Corroborating witness re Morales allegations. Also identified as forensic collection custodian.
8 | SVP Witness D | SVP, Post-Production | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-05 | 1:00 PM | Calderwood & Harkness LLP, Los Angeles office | Nadia Petrov | 1:10 | None | Yes | Completed | One of Hale's direct reports. Also identified as forensic collection custodian.
9 | Current Employee Witness E | Director, Development | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-06 | 10:00 AM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer; Nadia Petrov | 1:25 | None | Yes | Completed | Corroborating witness for Morales; present at Feb 3, 2023 company dinner.
10 | Current Employee Witness F | Director, Talent Relations | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-07 | 2:00 PM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer | 1:15 | None | Yes | Completed | Corroborating witness for Ngo; colleague to whom Ngo complained about off-site comments.
11 | Cameron Briggs | SVP of Production | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-08 | 2:00 PM | Calderwood & Harkness LLP, Los Angeles office | Nadia Petrov | 1:45 | None | Yes | Completed | Received reassigned Project Meridian and Project Halcyon from Whitfield on Feb 6, 2023. Discussed rationale provided by Hale for reassignment. Memo prepared June 8, 2023.
12 | Current Employee Witness G | Manager, Physical Production | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-09 | 10:00 AM | Calderwood & Harkness LLP, Los Angeles office | Nadia Petrov | 1:00 | None | Yes | Completed | Provided context on project reassignment of Project Meridian and Project Halcyon.
13 | Current Employee Witness H | VP, Business & Legal Affairs | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-12 | 9:30 AM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer | 1:30 | None | Yes | Completed | Corroborating witness for Morales; observed interactions during Vancouver production trip (Oct 2022).
14 | Current Employee Witness I | Director, Production Finance | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-13 | 1:00 PM | Calderwood & Harkness LLP, Los Angeles office | Nadia Petrov | 1:10 | None | Yes | Completed | Provided information on Project Meridian / Project Halcyon budgets and reassignment timeline.
15 | Current Employee Witness J | Senior Manager, HR Operations | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-14 | 10:00 AM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer; Nadia Petrov | 1:20 | None | Yes | Completed | Provided information on HR complaint-handling procedures and documentation practices at APS.
16 | Marcus Hale | President | Aurelius Pacific Studios Inc. | Subject | 2023-06-15 | 9:00 AM | Calderwood & Harkness LLP, 1999 Avenue of the Stars, Suite 2800, Los Angeles, CA 90067 | Bernard Crawford; Devon Archer | 4:20 | Graham Thornfield (Thornfield & Associates LLP, 10250 Constellation Blvd, Suite 1950, Los Angeles, CA 90067) | Yes | Completed | Subject of investigation. On paid administrative leave since May 3, 2023. Denied all allegations of sexual harassment and retaliation. Characterized complaints as performance-related grievances. 14-page written position statement submitted by Thornfield on June 5, 2023. Memo prepared June 15, 2023.
17 | Current Employee Witness K | Executive Assistant, Studio Office | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-19 | 10:00 AM | Calderwood & Harkness LLP, Los Angeles office | Nadia Petrov | 1:05 | None | Yes | Completed | Provided observations of Hale's office conduct and interactions with female staff.
18 | Current Employee Witness L | VP, Creative Development | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-20 | 2:00 PM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer | 1:15 | None | Yes | Completed | Corroborating witness for Morales; aware of Morales's account contemporaneously.
19 | Current Employee Witness M | Director, Scheduling & Operations | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-21 | 10:00 AM | Calderwood & Harkness LLP, Los Angeles office | Nadia Petrov | 1:00 | None | Yes | Completed | Corroborating witness for Ngo; present at Monarch Valley Resort off-site Feb 17–18, 2023.
20 | Serena Whitcomb | Former Executive Assistant to Hale | Aurelius Pacific Studios Inc. (former) | Former Employee | 2023-06-22 | 11:00 AM | Calderwood & Harkness LLP, Los Angeles office | Devon Archer | 1:30 | None | Yes | Completed | Employed April 2019 – September 2021. Made prior informal complaint against Hale in July 2021 alleging inappropriate comments. Discussed circumstances of departure. Memo prepared June 22, 2023.
21 | Current Employee Witness N | Coordinator, Talent Relations | Aurelius Pacific Studios Inc. | Current Employee | 2023-06-23 | 10:00 AM | Calderwood & Harkness LLP, Los Angeles office | Nadia Petrov | 0:55 | None | Yes | Completed | Reported that Ngo was excluded from three talent-relations strategy meetings in March–April 2023.
22 | Former Employee Witness O | Former Director, Production | Aurelius Pacific Studios Inc. (former) | Former Employee | 2023-06-26 | 11:00 AM | Telephone (witness in New York) | Devon Archer | 1:10 | None | Yes | Completed | Former APS employee. Provided background on Hale's management style and workplace culture.
23 | Former Employee Witness P | Former Manager, Studio Operations | Aurelius Pacific Studios Inc. (former) | Former Employee | 2023-06-28 | 2:00 PM | Telephone (witness in Atlanta) | Devon Archer | 1:05 | None | Yes | Completed | Former APS employee. Provided background on prior workplace concerns.
24 | Former Employee Witness Q | Former Associate, Development | Aurelius Pacific Studios Inc. (former) | Former Employee | 2023-06-30 | 10:00 AM | Telephone | Nadia Petrov | 0:50 | None | Yes | Completed | Former APS employee. Corroborating witness for Morales.
25 | Contractor Witness R | Line Producer | Third-party production company | Third-Party Contractor | 2023-07-05 | 10:00 AM | Telephone | Devon Archer | 1:00 | None | Yes (modified for non-employee) | Completed | Third-party production contractor. Present during Vancouver production trip (Oct 2022). Provided observations.
26 | Contractor Witness S | Unit Production Manager | Third-party production company | Third-Party Contractor | 2023-07-10 | 2:00 PM | Telephone | Nadia Petrov | 0:55 | None | Yes (modified for non-employee) | Completed | Third-party production contractor. Worked on Project Meridian. Provided context on production dynamics.
27 | Contractor Witness T | Casting Director | Third-party production company | Third-Party Contractor | 2023-07-14 | 10:00 AM | Telephone | Devon Archer | 1:05 | None | Yes (modified for non-employee) | Completed | Third-party production contractor. Final witness interview. Provided observations of Hale's interactions at production events.
[sheet: Summary Statistics]
Category / Metric | Count / Value
Total Witnesses Identified | 27
Interviews Completed | 27
Interviews Declined | 0
Interviews Pending / Scheduled | 0
--- Breakdown by Witness Category ---
Complainants | 3
Current Employees | 16
Former Employees | 4
Third-Party Production Contractors | 3
Subject (Marcus Hale) | 1
--- Timeline ---
First Interview Date | May 22, 2023
Last Interview Date | July 14, 2023
Total Interview Period (calendar days) | 54
--- Interviewer Assignments ---
Devon Archer (sole or co-interviewer) | 22
Nadia Petrov (sole or co-interviewer) | 19
Bernard Crawford (sole or co-interviewer) | 1
--- Interview Locations ---
In-person (C&H Los Angeles Office) | 21
Telephone | 6
--- Counsel Appearances ---
Interviews with opposing/personal counsel present | 1
Graham Thornfield present (Hale interview, June 15, 2023) | Yes
Sandra Reeves notified for Morales interview (May 22, 2023); did not attend | Notified / Did not attend
--- Upjohn Warning ---
Upjohn warning administered (all interviews) | 27
--- Average Interview Duration ---
Average duration (all interviews) | ~1 hr 30 min
Longest interview (Marcus Hale) | 4 hrs 20 min
Shortest interview (Former Employee Witness Q) | ~50 min
--- Corroborating Witnesses ---
Corroborating witnesses (Morales allegations) | 7
Corroborating witnesses (Ngo allegations) | 2
--- Matter Reference ---
Calderwood & Harkness Matter No. | 1017-00005
Client | Aurelius Global Media Group PLC
Subject Entity | Aurelius Pacific Studios Inc.
Investigation Subject | Marcus Hale, President
Investigation Opened | May 2, 2023
Last Updated | July 14, 2023
[sheet: Interview Chronology]
Week # | Week Beginning | Interviews Conducted | Witness Names | Cumulative Interviews | Milestone Notes
1 | 2023-05-22 | 2 | Jenna Morales; SVP Witness A | 2 | Interview phase commenced May 22, 2023
2 | 2023-05-29 | 3 | Claire Ngo; SVP Witness B; Darren Whitfield | 5
3 | 2023-06-05 | 6 | Victor Gallegos; SVP Witness C; SVP Witness D; Current Employee Witness E; Current Employee Witness F; Cameron Briggs | 11 | Hale written position statement received June 5, 2023
4 | 2023-06-12 | 4 | Current Employee Witness G; Current Employee Witness H; Current Employee Witness I; Current Employee Witness J; Marcus Hale (June 15 — 4 hrs 20 min, with Graham Thornfield present) | 16 | Subject interview conducted June 15, 2023
5 | 2023-06-19 | 5 | Current Employee Witness K; Current Employee Witness L; Current Employee Witness M; Serena Whitcomb; Current Employee Witness N | 21
6 | 2023-06-26 | 3 | Former Employee Witness O; Former Employee Witness P; Former Employee Witness Q | 24
7 | 2023-07-03 | 1 | Contractor Witness R | 25 | Sandra Reeves (Nakamura Reeves) follow-up letter received July 7, 2023
8 | 2023-07-10 | 2 | Contractor Witness S (July 10); Contractor Witness T (July 14) | 27 | Final witness interview completed July 14, 2023. All 27 interviews complete.
TOTAL | 27 | 27 | All 27 of 27 witness interviews completed.