1035-00001 · Client 1035 · Expert Engagement

expert-retention-letter-chandrasekaran.docx DOCUMENT M&A / Corporate

8 / 12 ← → ✕

Contract analysis Extract to table

CALDERWOOD & HARKNESS LLP Attorneys at Law

2029 Century Park East, Suite 3300 Los Angeles, California 90067

Telephone: (310) 556-8200 Facsimile: (310) 556-8201 www.calderwoodharkness.com

December 1, 2025

VIA Sundial Data Systems AND EMAIL

Dr. Priya Chandrasekaran Department of Economics Westbridge University 4500 University Drive Pasadena, California 91107

Re: Retention as Expert Economist — *United States v. Marguerite D. Fonseca*, Case No. 2:24-cr-00583-CMD, United States District Court for the Central District of California

Dear Dr. Chandrasekaran:

1. Introduction and Purpose of Engagement

Calderwood & Harkness LLP represents Marguerite D. Fonseca in connection with her sentencing in the above-referenced criminal matter, currently pending before the Honorable Catherine M. Driscoll, United States District Judge for the Central District of California. We write to confirm the terms under which Calderwood & Harkness LLP retains you as an expert economist to analyze and opine on the actual and intended financial loss calculations relevant to Ms. Fonseca's sentencing proceedings.

Your engagement is of critical importance to the defense. As set forth in greater detail below, the government's loss calculation, as adopted in the Presentence Investigation Report, contains significant methodological errors—including material double-counting of loss amounts and the failure to credit substantial sums that were reinvested into legitimate production activities. Your independent expert analysis of these issues will be essential to the Court's determination of the appropriate loss enhancement under the United States Sentencing Guidelines and the proper restitution amount.

Lisa Morrow, Lead Associate in the firm's Banking & Finance practice group, will serve as your primary point of contact for this engagement. Ms. Morrow is working under the supervision of Conrad Ashby, the Responsible Partner in the firm's White Collar Defense & Investigations practice, and Victoria Chambers, the Billing Partner for this matter within the same practice group. All substantive communications regarding the engagement should be directed to Ms. Morrow in the first instance, and she will coordinate with the broader defense team as necessary.

This engagement is made on behalf of the defendant, Ms. Fonseca, and all communications, materials, and work product generated in connection with this retention are protected by the attorney work product doctrine and all other applicable privileges. We ask that you treat all aspects of this engagement with the strictest confidence, as further detailed in Section 6 below.

2. Background of the Matter

To provide context for the scope of services described in this letter, we summarize below the relevant background of the case.

Ms. Fonseca is the founder and former Chief Executive Officer of Aurelia Pictures, Inc., a California corporation (California Secretary of State Entity No. C3276451), which maintained its principal offices at 8950 West Sunset Boulevard, Suite 1400, West Hollywood, California 90069. Aurelia Pictures was engaged in the development, production, and distribution of independent feature films. During the period relevant to this case, the company produced or co-produced approximately twelve feature films, several of which received theatrical and streaming distribution.

On September 18, 2025, following a three-week jury trial before Judge Driscoll, Ms. Fonseca was convicted on all seven counts of the operative indictment. Specifically, the jury returned guilty verdicts on four counts of wire fraud in violation of 18 U.S.C. § 1343, two counts of money laundering in violation of 18 U.S.C. § 1956(a)(1)(B)(i), and one count of conspiracy to commit wire fraud in violation of 18 U.S.C. § 1371. The prosecution was led by Assistant United States Attorneys Brenda K. Tillotson and Derek R. Huang of the Major Frauds Section of the United States Attorney's Office for the Central District of California.

The charged conduct spanned the period from approximately January 2018 through December 2022. The government alleged that Ms. Fonseca engaged in a scheme involving three primary categories of fraudulent activity: (a) the inflation of production budgets submitted to investors in order to divert the excess funds for unauthorized purposes, with production budgets allegedly inflated by approximately 25% to 40% above actual production costs; (b) the submission of fraudulent applications to the California Film Commission under the State's Film & Television Tax Credit Program, which resulted in the improper receipt of transferable tax credits; and (c) the commingling and diversion of investor funds into Aurelia Pictures' general operating accounts and, in certain instances, into personal accounts controlled by Ms. Fonseca.

The sentencing hearing is currently scheduled for March 6, 2026. The Presentence Investigation Report (hereinafter, the "PSR") was prepared by United States Probation Officer Michael T. Brennan and was disclosed to the parties on November 3, 2025. As discussed more fully in Section 3 below, the PSR adopts the government's loss calculation in its entirety, resulting in a loss enhancement and advisory Guidelines range that the defense believes are materially overstated.

It is relevant to note that Ms. Fonseca was represented at trial by Harrison J. Kerrigan of Kerrigan & Wolfe LLP. Calderwood & Harkness LLP was retained on November 12, 2025, specifically for purposes of sentencing representation, following Ms. Fonseca's decision to engage new counsel for the post-trial phase of the proceedings. Our firm has conducted an extensive review of the trial record, the PSR, and the underlying financial documentation, and we have identified the loss calculation issues that form the core of your proposed engagement.

3. Scope of Expert Services

Dr. Chandrasekaran is retained to perform the following services in connection with Ms. Fonseca's sentencing. Each category of work is described in detail below.

3.1 Analysis of the Government's Loss Calculation

You are asked to review and analyze the government's total alleged loss figure of $14.7 million, which the PSR has adopted without modification. The government's calculation comprises three components, each of which requires independent scrutiny:

(a) Inflated Production Budget Diversions — $6.1 Million. The government alleges that Ms. Fonseca inflated the production budgets for five Aurelia Pictures productions, submitting budgets to investors that were approximately 25% to 40% higher than actual production costs. The government attributes $6.1 million in losses to this category, representing the aggregate difference between the budgets presented to investors and the actual costs incurred in producing the five films at issue. Your analysis should evaluate the methodology by which the government calculated the "inflated" portion of each budget, the reliability of the baseline cost figures used, and whether the government's approach properly accounts for legitimate production expenditures, contingencies, and industry-standard budget practices.

(b) Fraudulently Obtained California Film Commission Tax Credits — $2.8 Million. The government alleges that Ms. Fonseca submitted fraudulent applications to the California Film Commission under the Film & Television Tax Credit Program for three of the five productions, resulting in the issuance of $2.8 million in transferable tax credits to which Aurelia Pictures was not entitled. Your analysis should review the basis for the government's claim that the credits were fraudulently obtained, including the relationship between the inflated budget figures and the credit applications, and should assess whether the full $2.8 million represents an actual loss attributable to the charged conduct.

(c) Diverted Investor Funds — $5.8 Million. The government alleges that Ms. Fonseca commingled and diverted approximately $5.8 million in investor funds, routing those funds into Aurelia Pictures' general operating accounts and, in certain instances, into personal accounts. Your analysis should trace the fund flows underlying this category and evaluate the extent to which the funds attributed to this category overlap with funds already counted in the inflated budget diversion category.

In connection with this analysis, you are further asked to review the trial testimony and underlying methodology of Dr. Ramesh Patel, CPA, CFF, of Hargrove, Patel & Sullivan LLP (200 Park Avenue South, Suite 3100, New York, New York 10003), who served as the government's forensic accounting expert at trial. Dr. Patel prepared the loss analysis upon which the government relied in its sentencing submissions and which the Probation Officer adopted in the PSR. Your review should include an assessment of the methodological soundness of Dr. Patel's analysis, any assumptions or limitations in his approach, and any errors or omissions that affect the reliability of his conclusions.

3.2 Double-Counting Analysis

A central issue in the defense's challenge to the PSR's loss calculation is the apparent double-counting of loss amounts across the government's three loss categories. Specifically, our preliminary analysis indicates that approximately $4.3 million in funds appear in both the inflated budget diversion category ($6.1 million) and the diverted investor funds category ($5.8 million). This overlap arises because a substantial portion of the funds that the government characterizes as "diverted investor funds" are the same funds that investors contributed toward production budgets that the government separately characterizes as "inflated."

You are asked to identify and quantify this overlap with precision, tracing specific fund flows and transactions to demonstrate that the government's methodology counts the same dollars twice. Your analysis should demonstrate that the correct actual loss figure, after the elimination of double-counting, is approximately $10.4 million ($14.7 million minus $4.3 million in double-counted amounts). This analysis will be a cornerstone of the defense's objections to the PSR and must be supported by detailed fund-flow analysis and clear, demonstrable transaction-level evidence.

3.3 Reinvested Funds Analysis

In addition to the double-counting issue, the defense contends that the loss calculation should be further reduced to account for approximately $2.1 million in diverted funds that were ultimately reinvested into legitimate production activities of Aurelia Pictures. While these funds may have been initially diverted or commingled in a manner consistent with the charged conduct, they were subsequently deployed for bona fide production purposes—including payments to vendors, crew, and post-production facilities—that generated value for the productions in which investors had invested.

You are asked to analyze the approximately $2.1 million in reinvested funds, tracing the flow of these funds from the accounts into which they were initially diverted back into legitimate production expenditures. You are further asked to opine on whether, under the applicable sentencing guidelines methodology, such reinvested amounts should be excluded from the intended loss calculation, taking into account the Guidelines commentary, relevant case law, and accepted economic principles regarding loss measurement. This analysis should support the defense's position that the correct intended loss figure is approximately $8.3 million ($10.4 million minus $2.1 million in reinvested funds).

3.4 Sentencing Guidelines Impact Analysis

You are asked to analyze the implications of the corrected loss figure for the loss enhancement under U.S.S.G. § 2B1.1(b)(1), which provides for specific offense level enhancements based on the amount of loss attributable to the offense.

The PSR currently applies a +18 level enhancement based on a loss amount of $14.7 million. Under § 2B1.1(b)(1)(J), a loss of more than $9,500,000 but not more than $25,000,000 results in an 18-level increase to the base offense level. The defense contends that an intended loss of $8.3 million falls within the range specified in § 2B1.1(b)(1)(I)—more than $6,500,000 but not more than $9,500,000—which warrants only a +16 level enhancement. This two-level reduction, while it may appear modest on its face, would have a meaningful impact on the advisory Guidelines sentencing range.

Specifically, the PSR calculates a Total Offense Level of 31, based on a base offense level of 7 (under § 2B1.1(a)(1)), plus an 18-level loss enhancement, plus a 2-level enhancement for the number of victims (§ 2B1.1(b)(2)), plus a 2-level enhancement for abuse of a position of trust (§ 3B1.3), plus a 2-level enhancement for use of sophisticated means (§ 2B1.1(b)(10)). At Criminal History Category I—which is Ms. Fonseca's criminal history category, as she has no prior criminal record—a Total Offense Level of 31 yields an advisory Guidelines range of 108 to 135 months of imprisonment.

The defense contends that the correct Total Offense Level is 27, calculated as follows: base offense level of 7, plus a 16-level loss enhancement (based on the corrected intended loss of $8.3 million), plus a 2-level enhancement for the number of victims, plus a 2-level enhancement for abuse of a position of trust, and without the sophisticated means enhancement (which the defense is separately challenging through other objections to the PSR). At Criminal History Category I, a Total Offense Level of 27 yields an advisory Guidelines range of 70 to 87 months of imprisonment. This represents a reduction of approximately 38 to 48 months from the range calculated in the PSR—a difference of significant consequence to Ms. Fonseca.

Your analysis should clearly articulate the basis for placing the corrected loss figure within the applicable Guidelines range and should address any counterarguments that the government or Probation Office may raise regarding the proper methodology for loss calculation.

3.5 Restitution Analysis

You are also asked to analyze the appropriate restitution amount under the Mandatory Victims Restitution Act, 18 U.S.C. § 3663A. The government has submitted restitution claims on behalf of the identified victims, and the defense believes that certain of these claims are overstated or include speculative components that are not properly compensable under the statute.

You should review the claims submitted by the following identified victims:

(a) Brindoval Investors Group LP. Brindoval Investors Group LP (Managing Partner: Theodore R. Blackwell; principal office: 150 North Wacker Drive, Suite 2200, Chicago, Illinois 60606) invested a total of $8.2 million across three Aurelia Pictures productions: Meridian, The Cartographer's Daughter, and Blue Signal. In addition to seeking restitution for its invested capital, Brindoval has submitted a claim for $3.1 million in lost profits, representing the returns it alleges it would have earned had the invested funds been properly deployed. Brindoval is represented by Susan R. Aldrich of Aldrich & McBride LLP. The defense intends to challenge the $3.1 million lost profits claim as speculative and not compensable under § 3663A.

(b) Lakeshore Capital Partners LLC. Lakeshore Capital Partners LLC (Managing Member: Diana Caruso; principal office: 2300 Main Street, Suite 510, Irvine, California 92614) invested a total of $3.9 million across two Aurelia Pictures productions: Glass Meridian and The Understory. Lakeshore's restitution claim is limited to its invested capital and does not include a lost profits component.

(c) California Film Commission. The California Film Commission has submitted a claim for $2.8 million, representing the full amount of the tax credits that the government alleges were fraudulently obtained.

(d) Individual Investors. Five individual investors have submitted combined restitution claims totaling approximately $2.6 million, representing their respective investments in various Aurelia Pictures productions.

You are asked to opine on the proper methodology for calculating restitution under § 3663A, with particular attention to distinguishing between compensable actual losses sustained by the victims and speculative or consequential claims—most notably, Brindoval's $3.1 million claimed lost profits. Your analysis should address the legal and economic bases for excluding lost profits from the restitution calculation, including the distinction between actual loss and anticipated gain, the speculative nature of projected film investment returns, and the applicable case law in the Ninth Circuit regarding the scope of restitution under the Mandatory Victims Restitution Act.

3.6 Preparation of Written Report

You are asked to prepare a comprehensive written expert report setting forth your methodology, analysis, findings, and opinions in connection with each of the foregoing areas. The report should be of a quality and rigor suitable for submission to the Court in support of the following defense filings:

(a) the Defendant's Objections to the Presentence Investigation Report;

(b) the Defendant's Sentencing Memorandum; and

The report must be completed no later than January 31, 2026, in order to allow the defense team adequate time to incorporate your findings and opinions into the sentencing submissions, which are due in February 2026. We recognize that this timeline is demanding and will work to ensure that all necessary materials are provided to you promptly. Please advise immediately if you anticipate any difficulty meeting this deadline.

3.7 Testimony. You should be prepared to testify at the sentencing hearing currently scheduled for March 6, 2026, before the Honorable Catherine M. Driscoll, at the United States Courthouse, 350 West 1st Street, Los Angeles, California 90012, if requested by the defense team. Your testimony would address the opinions set forth in your written report, including your analysis of the government's loss calculation, the double-counting and reinvestment issues, the implications for the Guidelines loss enhancement, and the proper restitution methodology.

In addition, potential testimony may be required at any evidentiary hearing on the defense's objections to the PSR, should the Court determine that such a hearing is warranted. We will provide you with reasonable advance notice of any scheduled hearing or testimony date and will work with you to prepare accordingly.

4. Materials to Be Provided

Calderwood & Harkness LLP will provide you with the following materials for review in connection with this engagement. All materials will be provided subject to the confidentiality protections set forth in Section 6 of this letter, and you should maintain all materials in a secure location, separate from your other professional files.

(a) The Presentence Investigation Report (PSR) dated November 3, 2025, prepared by U.S. Probation Officer Michael T. Brennan, including all appendices and attachments thereto.

(b) The federal indictment in United States v. Marguerite D. Fonseca, Case No. 2:24-cr-00583-CMD, returned by the grand jury on April 10, 2024.

(c) Trial transcripts from the three-week jury trial, including in particular the direct and cross-examination testimony of Dr. Ramesh Patel of Hargrove, Patel & Sullivan LLP, the government's forensic accounting expert.

(d) Financial records of Aurelia Pictures, Inc., including production budgets, bank account statements, general ledger records, and accounting records available through the court-appointed receivership. The receiver is Nathaniel W. Prescott of Ridgeway Advisory Group LLC, appointed on August 2, 2025, in California Film Commission v. Aurelia Pictures, Inc., Los Angeles Superior Court Case No. 25STCV08312.

(e) California Film Commission tax credit applications and all supporting documentation submitted in connection with the three productions at issue in the tax credit fraud counts.

(f) Investor agreements, subscription documents, private placement memoranda, and fund flow documentation for the productions involving Brindoval Investors Group LP and Lakeshore Capital Partners LLC.

(g) The government's restitution submissions, including the victim impact statements filed by Aldrich & McBride LLP on behalf of Brindoval Investors Group LP and any declarations or supporting documentation submitted by other identified victims.

(h) The defense's internal loss calculation analysis prepared by Lisa Morrow, Lead Associate, and Peter Vassiliev, Senior Associate, of Calderwood & Harkness LLP.

(i) Any additional documents, data, or materials as may be identified during the course of the engagement and deemed relevant to your analysis.

We anticipate that the initial set of materials will be delivered to you within five business days of the execution of this letter. Supplemental materials will be provided on a rolling basis as they become available or as the scope of your analysis dictates.

5. Compensation

Dr. Chandrasekaran will be compensated for her professional services in connection with this engagement as follows:

Hourly Rate. You will be compensated at the rate of $675.00 per hour for all professional services rendered, including but not limited to document review, data analysis, economic modeling, conferences with counsel (whether in person, by telephone, or by videoconference), report preparation, deposition or hearing preparation, and testimony at hearings or proceedings.

Travel Time. Time spent traveling in connection with this engagement will be billed at one-half of the standard hourly rate, i.e., $337.50 per hour.

Expenses. Reasonable out-of-pocket expenses incurred in connection with this engagement will be reimbursed at cost upon submission of receipts. Reimbursable expenses include, without limitation, travel costs (airfare, ground transportation, parking), lodging, meals incurred during travel, copying and printing charges, and the cost of research materials or databases accessed specifically for this engagement. Any single expense item exceeding $500.00 should be approved in advance by Lisa Morrow.

Invoicing. Invoices should be submitted on a monthly basis to Calderwood & Harkness LLP, to the attention of Lisa Morrow, at the firm's Los Angeles office address: 2029 Century Park East, Suite 3300, Los Angeles, California 90067. Each invoice should include a reasonably detailed description of the services performed, the date on which each service was performed, the time expended, and an itemization of any out-of-pocket expenses for which reimbursement is sought.

Payment Terms. Payment will be made within thirty (30) days of the firm's receipt of each invoice (net 30 days).

Retainer. An initial retainer in the amount of $10,000.00 is requested and should be deposited into your trust or operating account upon execution of this letter. The retainer will be held and applied against the final invoice or invoices rendered in connection with this engagement. If the total fees and expenses incurred are less than the retainer amount, the unused balance will be refunded promptly upon the conclusion of the engagement.

6. Confidentiality and Privilege

All materials provided to you in connection with this engagement, and all work product generated by you in connection with this engagement—including notes, drafts, memoranda, data analyses, spreadsheets, communications, and reports—are provided and prepared at the direction of counsel for Ms. Fonseca and are protected by the attorney-client privilege and the attorney work product doctrine. These protections are of paramount importance given the nature of the pending sentencing proceedings and the sensitivity of the underlying materials.

You shall not disclose any materials, communications, analysis, findings, opinions, or other information related to this engagement to any third party without the prior written consent of Calderwood & Harkness LLP. This prohibition extends to colleagues, research assistants, family members, and any other person not authorized by the firm to receive such information. To the extent you require the assistance of a research assistant or associate in performing your analysis, please discuss this with Lisa Morrow in advance so that appropriate confidentiality protections can be arranged.

In the event you are contacted by any government representative (including the U.S. Attorney's Office, the Federal Bureau of Investigation, the U.S. Probation Office, or any other law enforcement or regulatory agency), opposing counsel, any member of the media, or any other third party regarding this matter or your retention by the defense, you shall immediately notify Lisa Morrow or Conrad Ashby and shall not provide any information, documents, or materials without counsel's express authorization. This instruction applies regardless of the manner of contact—whether by telephone, email, letter, in-person visit, or otherwise.

You should be aware that, in the event you are designated as a testifying expert and called to provide testimony at the sentencing hearing or any evidentiary hearing, certain privilege protections may be waived as to your opinions and the bases and reasons therefor, as required by applicable rules of criminal procedure and evidence. Counsel will advise you well in advance of any such designation and will discuss with you the scope of any potential waiver so that you may prepare accordingly.

7. Independence and Objectivity

You are retained as an independent expert, and Calderwood & Harkness LLP expects you to render your honest, objective professional opinions based on your thorough and independent analysis of the available data and relevant economic principles. Your credibility as an expert is of the utmost importance to the defense, and it depends upon the integrity and objectivity of your analysis.

Calderwood & Harkness LLP does not seek to influence or dictate the substance of your opinions. If your analysis leads you to conclusions that differ from the defense's preliminary assessments, we expect you to communicate those conclusions candidly and promptly. The firm retains the sole right to determine whether and how to use your work product in the sentencing proceedings, including the decision whether to submit your report to the Court, whether to call you as a witness, and how to present your findings in the defense's submissions.

8. Conflicts of Interest

By executing this letter, you confirm that you have conducted a reasonable inquiry and have determined that you have no prior professional or personal relationship with any of the following individuals or entities that would impair your objectivity or create a conflict of interest in connection with this engagement:

(a) The prosecution team, including Assistant United States Attorney Brenda K. Tillotson and Assistant United States Attorney Derek R. Huang;

(b) The government's forensic accounting expert, Dr. Ramesh Patel, CPA, CFF, of Hargrove, Patel & Sullivan LLP;

(d) The United States Probation Officer assigned to this matter, Michael T. Brennan;

(e) Any of the identified victims, including Brindoval Investors Group LP, Lakeshore Capital Partners LLC, the California Film Commission, or any of the individual investors; and

(f) Counsel for any of the identified victims, including Susan R. Aldrich of Aldrich & McBride LLP.

You shall promptly notify Calderwood & Harkness LLP of any actual or potential conflicts of interest that may arise during the course of the engagement, including any new professional engagements, consulting arrangements, or personal relationships that could be perceived as impairing your independence or objectivity.

9. Term and Termination

This engagement shall commence upon your execution of this letter and shall continue through the completion of the sentencing proceedings in United States v. Marguerite D. Fonseca, currently scheduled for March 6, 2026. The engagement shall also encompass any post-sentencing matters for which your services may be reasonably required, including without limitation any proceedings related to restitution determinations, any resentencing proceedings, or any appellate proceedings in which your expert analysis may be relevant.

Either party may terminate this engagement upon fourteen (14) days' prior written notice to the other party. In the event of termination, you shall promptly return to Calderwood & Harkness LLP all materials provided to you in connection with this engagement, as well as all work product generated by you, including notes, drafts, data files, and analyses. Termination shall not affect any confidentiality or privilege obligations, which shall survive termination of the engagement indefinitely.

Calderwood & Harkness LLP will remain responsible for the payment of all fees and expenses properly incurred through the effective date of termination, in accordance with the compensation terms set forth in Section 5 above.

10. Acceptance and Counterparts

If the foregoing terms are acceptable to you, please indicate your acceptance by signing in the space provided below and returning a copy of this fully executed letter to Lisa Morrow at the firm's Los Angeles office address or by email to lmorrow@calderwoodharkness.com. We request that the signed letter be returned within ten (10) business days of your receipt.

This letter may be executed in counterparts, including by electronic signature (e.g., Brightwater Software or similar platforms), each of which shall be deemed an original and all of which together shall constitute one and the same instrument.

We are confident that your expertise in applied economics and financial loss analysis will be invaluable to the defense team as we work to ensure a just and fair outcome for Ms. Fonseca at sentencing. The issues presented in this case—particularly the double-counting errors and the failure to account for reinvested funds—are precisely the types of complex economic questions that require the rigorous, independent analysis that you are uniquely qualified to provide. We look forward to working with you on this important engagement and to a productive collaboration in the weeks ahead.

Please do not hesitate to contact Lisa Morrow at (310) 556-8214 or lmorrow@calderwoodharkness.com, or Conrad Ashby at (310) 556-8207 or cashby@calderwoodharkness.com, should you have any questions regarding this letter or the engagement.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Lisa Morrow Lead Associate, Banking & Finance Calderwood & Harkness LLP 2029 Century Park East, Suite 3300 Los Angeles, California 90067 Telephone: (310) 556-8214

Email: lmorrow@calderwoodharkness.com

Approved by:

________________________________________

Conrad Ashby Responsible Partner, White Collar Defense & Investigations Calderwood & Harkness LLP

AGREED AND ACCEPTED:

By executing below, Dr. Priya Chandrasekaran acknowledges that she has read, understood, and agrees to be bound by the terms and conditions set forth in this Expert Retention Letter.

________________________________________

Dr. Priya Chandrasekaran, Ph.D. Department of Economics Westbridge University

Date: ________

cc: Conrad Ashby, Calderwood & Harkness LLP Victoria Chambers, Calderwood & Harkness LLP Peter Vassiliev, Calderwood & Harkness LLP

Enclosures: (1) Conflict of Interest Disclosure Form (2) W-9 Request for Taxpayer Identification Number and Certification

CALDERWOOD & HARKNESS LLP Attorneys at Law
2029 Century Park East, Suite 3300 Los Angeles, California 90067
Telephone: (310) 556-8200 Facsimile: (310) 556-8201 www.calderwoodharkness.com
December 1, 2025
VIA Sundial Data Systems AND EMAIL
Dr. Priya Chandrasekaran Department of Economics Westbridge University 4500 University Drive Pasadena, California 91107
Re: Retention as Expert Economist — *United States v. Marguerite D. Fonseca*, Case No. 2:24-cr-00583-CMD, United States District Court for the Central District of California
Dear Dr. Chandrasekaran:
1. Introduction and Purpose of Engagement
Calderwood & Harkness LLP represents Marguerite D. Fonseca in connection with her sentencing in the above-referenced criminal matter, currently pending before the Honorable Catherine M. Driscoll, United States District Judge for the Central District of California. We write to confirm the terms under which Calderwood & Harkness LLP retains you as an expert economist to analyze and opine on the actual and intended financial loss calculations relevant to Ms. Fonseca's sentencing proceedings.
Your engagement is of critical importance to the defense. As set forth in greater detail below, the government's loss calculation, as adopted in the Presentence Investigation Report, contains significant methodological errors—including material double-counting of loss amounts and the failure to credit substantial sums that were reinvested into legitimate production activities. Your independent expert analysis of these issues will be essential to the Court's determination of the appropriate loss enhancement under the United States Sentencing Guidelines and the proper restitution amount.
Lisa Morrow, Lead Associate in the firm's Banking & Finance practice group, will serve as your primary point of contact for this engagement. Ms. Morrow is working under the supervision of Conrad Ashby, the Responsible Partner in the firm's White Collar Defense & Investigations practice, and Victoria Chambers, the Billing Partner for this matter within the same practice group. All substantive communications regarding the engagement should be directed to Ms. Morrow in the first instance, and she will coordinate with the broader defense team as necessary.
This engagement is made on behalf of the defendant, Ms. Fonseca, and all communications, materials, and work product generated in connection with this retention are protected by the attorney work product doctrine and all other applicable privileges. We ask that you treat all aspects of this engagement with the strictest confidence, as further detailed in Section 6 below.
2. Background of the Matter
To provide context for the scope of services described in this letter, we summarize below the relevant background of the case.
Ms. Fonseca is the founder and former Chief Executive Officer of Aurelia Pictures, Inc., a California corporation (California Secretary of State Entity No. C3276451), which maintained its principal offices at 8950 West Sunset Boulevard, Suite 1400, West Hollywood, California 90069. Aurelia Pictures was engaged in the development, production, and distribution of independent feature films. During the period relevant to this case, the company produced or co-produced approximately twelve feature films, several of which received theatrical and streaming distribution.
On September 18, 2025, following a three-week jury trial before Judge Driscoll, Ms. Fonseca was convicted on all seven counts of the operative indictment. Specifically, the jury returned guilty verdicts on four counts of wire fraud in violation of 18 U.S.C. § 1343, two counts of money laundering in violation of 18 U.S.C. § 1956(a)(1)(B)(i), and one count of conspiracy to commit wire fraud in violation of 18 U.S.C. § 1371. The prosecution was led by Assistant United States Attorneys Brenda K. Tillotson and Derek R. Huang of the Major Frauds Section of the United States Attorney's Office for the Central District of California.
The charged conduct spanned the period from approximately January 2018 through December 2022. The government alleged that Ms. Fonseca engaged in a scheme involving three primary categories of fraudulent activity: (a) the inflation of production budgets submitted to investors in order to divert the excess funds for unauthorized purposes, with production budgets allegedly inflated by approximately 25% to 40% above actual production costs; (b) the submission of fraudulent applications to the California Film Commission under the State's Film & Television Tax Credit Program, which resulted in the improper receipt of transferable tax credits; and (c) the commingling and diversion of investor funds into Aurelia Pictures' general operating accounts and, in certain instances, into personal accounts controlled by Ms. Fonseca.
The sentencing hearing is currently scheduled for March 6, 2026. The Presentence Investigation Report (hereinafter, the "PSR") was prepared by United States Probation Officer Michael T. Brennan and was disclosed to the parties on November 3, 2025. As discussed more fully in Section 3 below, the PSR adopts the government's loss calculation in its entirety, resulting in a loss enhancement and advisory Guidelines range that the defense believes are materially overstated.
It is relevant to note that Ms. Fonseca was represented at trial by Harrison J. Kerrigan of Kerrigan & Wolfe LLP. Calderwood & Harkness LLP was retained on November 12, 2025, specifically for purposes of sentencing representation, following Ms. Fonseca's decision to engage new counsel for the post-trial phase of the proceedings. Our firm has conducted an extensive review of the trial record, the PSR, and the underlying financial documentation, and we have identified the loss calculation issues that form the core of your proposed engagement.
3. Scope of Expert Services
Dr. Chandrasekaran is retained to perform the following services in connection with Ms. Fonseca's sentencing. Each category of work is described in detail below.
3.1 Analysis of the Government's Loss Calculation
You are asked to review and analyze the government's total alleged loss figure of $14.7 million, which the PSR has adopted without modification. The government's calculation comprises three components, each of which requires independent scrutiny:
(a) Inflated Production Budget Diversions — $6.1 Million. The government alleges that Ms. Fonseca inflated the production budgets for five Aurelia Pictures productions, submitting budgets to investors that were approximately 25% to 40% higher than actual production costs. The government attributes $6.1 million in losses to this category, representing the aggregate difference between the budgets presented to investors and the actual costs incurred in producing the five films at issue. Your analysis should evaluate the methodology by which the government calculated the "inflated" portion of each budget, the reliability of the baseline cost figures used, and whether the government's approach properly accounts for legitimate production expenditures, contingencies, and industry-standard budget practices.
(b) Fraudulently Obtained California Film Commission Tax Credits — $2.8 Million. The government alleges that Ms. Fonseca submitted fraudulent applications to the California Film Commission under the Film & Television Tax Credit Program for three of the five productions, resulting in the issuance of $2.8 million in transferable tax credits to which Aurelia Pictures was not entitled. Your analysis should review the basis for the government's claim that the credits were fraudulently obtained, including the relationship between the inflated budget figures and the credit applications, and should assess whether the full $2.8 million represents an actual loss attributable to the charged conduct.
(c) Diverted Investor Funds — $5.8 Million. The government alleges that Ms. Fonseca commingled and diverted approximately $5.8 million in investor funds, routing those funds into Aurelia Pictures' general operating accounts and, in certain instances, into personal accounts. Your analysis should trace the fund flows underlying this category and evaluate the extent to which the funds attributed to this category overlap with funds already counted in the inflated budget diversion category.
In connection with this analysis, you are further asked to review the trial testimony and underlying methodology of Dr. Ramesh Patel, CPA, CFF, of Hargrove, Patel & Sullivan LLP (200 Park Avenue South, Suite 3100, New York, New York 10003), who served as the government's forensic accounting expert at trial. Dr. Patel prepared the loss analysis upon which the government relied in its sentencing submissions and which the Probation Officer adopted in the PSR. Your review should include an assessment of the methodological soundness of Dr. Patel's analysis, any assumptions or limitations in his approach, and any errors or omissions that affect the reliability of his conclusions.
3.2 Double-Counting Analysis
A central issue in the defense's challenge to the PSR's loss calculation is the apparent double-counting of loss amounts across the government's three loss categories. Specifically, our preliminary analysis indicates that approximately $4.3 million in funds appear in both the inflated budget diversion category ($6.1 million) and the diverted investor funds category ($5.8 million). This overlap arises because a substantial portion of the funds that the government characterizes as "diverted investor funds" are the same funds that investors contributed toward production budgets that the government separately characterizes as "inflated."
You are asked to identify and quantify this overlap with precision, tracing specific fund flows and transactions to demonstrate that the government's methodology counts the same dollars twice. Your analysis should demonstrate that the correct actual loss figure, after the elimination of double-counting, is approximately $10.4 million ($14.7 million minus $4.3 million in double-counted amounts). This analysis will be a cornerstone of the defense's objections to the PSR and must be supported by detailed fund-flow analysis and clear, demonstrable transaction-level evidence.
3.3 Reinvested Funds Analysis
In addition to the double-counting issue, the defense contends that the loss calculation should be further reduced to account for approximately $2.1 million in diverted funds that were ultimately reinvested into legitimate production activities of Aurelia Pictures. While these funds may have been initially diverted or commingled in a manner consistent with the charged conduct, they were subsequently deployed for bona fide production purposes—including payments to vendors, crew, and post-production facilities—that generated value for the productions in which investors had invested.
You are asked to analyze the approximately $2.1 million in reinvested funds, tracing the flow of these funds from the accounts into which they were initially diverted back into legitimate production expenditures. You are further asked to opine on whether, under the applicable sentencing guidelines methodology, such reinvested amounts should be excluded from the intended loss calculation, taking into account the Guidelines commentary, relevant case law, and accepted economic principles regarding loss measurement. This analysis should support the defense's position that the correct intended loss figure is approximately $8.3 million ($10.4 million minus $2.1 million in reinvested funds).
3.4 Sentencing Guidelines Impact Analysis
You are asked to analyze the implications of the corrected loss figure for the loss enhancement under U.S.S.G. § 2B1.1(b)(1), which provides for specific offense level enhancements based on the amount of loss attributable to the offense.
The PSR currently applies a +18 level enhancement based on a loss amount of $14.7 million. Under § 2B1.1(b)(1)(J), a loss of more than $9,500,000 but not more than $25,000,000 results in an 18-level increase to the base offense level. The defense contends that an intended loss of $8.3 million falls within the range specified in § 2B1.1(b)(1)(I)—more than $6,500,000 but not more than $9,500,000—which warrants only a +16 level enhancement. This two-level reduction, while it may appear modest on its face, would have a meaningful impact on the advisory Guidelines sentencing range.
Specifically, the PSR calculates a Total Offense Level of 31, based on a base offense level of 7 (under § 2B1.1(a)(1)), plus an 18-level loss enhancement, plus a 2-level enhancement for the number of victims (§ 2B1.1(b)(2)), plus a 2-level enhancement for abuse of a position of trust (§ 3B1.3), plus a 2-level enhancement for use of sophisticated means (§ 2B1.1(b)(10)). At Criminal History Category I—which is Ms. Fonseca's criminal history category, as she has no prior criminal record—a Total Offense Level of 31 yields an advisory Guidelines range of 108 to 135 months of imprisonment.
The defense contends that the correct Total Offense Level is 27, calculated as follows: base offense level of 7, plus a 16-level loss enhancement (based on the corrected intended loss of $8.3 million), plus a 2-level enhancement for the number of victims, plus a 2-level enhancement for abuse of a position of trust, and without the sophisticated means enhancement (which the defense is separately challenging through other objections to the PSR). At Criminal History Category I, a Total Offense Level of 27 yields an advisory Guidelines range of 70 to 87 months of imprisonment. This represents a reduction of approximately 38 to 48 months from the range calculated in the PSR—a difference of significant consequence to Ms. Fonseca.
Your analysis should clearly articulate the basis for placing the corrected loss figure within the applicable Guidelines range and should address any counterarguments that the government or Probation Office may raise regarding the proper methodology for loss calculation.
3.5 Restitution Analysis
You are also asked to analyze the appropriate restitution amount under the Mandatory Victims Restitution Act, 18 U.S.C. § 3663A. The government has submitted restitution claims on behalf of the identified victims, and the defense believes that certain of these claims are overstated or include speculative components that are not properly compensable under the statute.
You should review the claims submitted by the following identified victims:
(a) Brindoval Investors Group LP. Brindoval Investors Group LP (Managing Partner: Theodore R. Blackwell; principal office: 150 North Wacker Drive, Suite 2200, Chicago, Illinois 60606) invested a total of $8.2 million across three Aurelia Pictures productions: Meridian, The Cartographer's Daughter, and Blue Signal. In addition to seeking restitution for its invested capital, Brindoval has submitted a claim for $3.1 million in lost profits, representing the returns it alleges it would have earned had the invested funds been properly deployed. Brindoval is represented by Susan R. Aldrich of Aldrich & McBride LLP. The defense intends to challenge the $3.1 million lost profits claim as speculative and not compensable under § 3663A.
(b) Lakeshore Capital Partners LLC. Lakeshore Capital Partners LLC (Managing Member: Diana Caruso; principal office: 2300 Main Street, Suite 510, Irvine, California 92614) invested a total of $3.9 million across two Aurelia Pictures productions: Glass Meridian and The Understory. Lakeshore's restitution claim is limited to its invested capital and does not include a lost profits component.
(c) California Film Commission. The California Film Commission has submitted a claim for $2.8 million, representing the full amount of the tax credits that the government alleges were fraudulently obtained.
(d) Individual Investors. Five individual investors have submitted combined restitution claims totaling approximately $2.6 million, representing their respective investments in various Aurelia Pictures productions.
You are asked to opine on the proper methodology for calculating restitution under § 3663A, with particular attention to distinguishing between compensable actual losses sustained by the victims and speculative or consequential claims—most notably, Brindoval's $3.1 million claimed lost profits. Your analysis should address the legal and economic bases for excluding lost profits from the restitution calculation, including the distinction between actual loss and anticipated gain, the speculative nature of projected film investment returns, and the applicable case law in the Ninth Circuit regarding the scope of restitution under the Mandatory Victims Restitution Act.
3.6 Preparation of Written Report
You are asked to prepare a comprehensive written expert report setting forth your methodology, analysis, findings, and opinions in connection with each of the foregoing areas. The report should be of a quality and rigor suitable for submission to the Court in support of the following defense filings:
(a) the Defendant's Objections to the Presentence Investigation Report;
(b) the Defendant's Sentencing Memorandum; and
(c) the Defendant's Motion for Downward Variance under 18 U.S.C. § 3553(a).
The report must be completed no later than January 31, 2026, in order to allow the defense team adequate time to incorporate your findings and opinions into the sentencing submissions, which are due in February 2026. We recognize that this timeline is demanding and will work to ensure that all necessary materials are provided to you promptly. Please advise immediately if you anticipate any difficulty meeting this deadline.
3.7 Testimony.  You should be prepared to testify at the sentencing hearing currently scheduled for March 6, 2026, before the Honorable Catherine M. Driscoll, at the United States Courthouse, 350 West 1st Street, Los Angeles, California 90012, if requested by the defense team. Your testimony would address the opinions set forth in your written report, including your analysis of the government's loss calculation, the double-counting and reinvestment issues, the implications for the Guidelines loss enhancement, and the proper restitution methodology.
In addition, potential testimony may be required at any evidentiary hearing on the defense's objections to the PSR, should the Court determine that such a hearing is warranted. We will provide you with reasonable advance notice of any scheduled hearing or testimony date and will work with you to prepare accordingly.
4. Materials to Be Provided
Calderwood & Harkness LLP will provide you with the following materials for review in connection with this engagement. All materials will be provided subject to the confidentiality protections set forth in Section 6 of this letter, and you should maintain all materials in a secure location, separate from your other professional files.
(a) The Presentence Investigation Report (PSR) dated November 3, 2025, prepared by U.S. Probation Officer Michael T. Brennan, including all appendices and attachments thereto.
(b) The federal indictment in United States v. Marguerite D. Fonseca, Case No. 2:24-cr-00583-CMD, returned by the grand jury on April 10, 2024.
(c) Trial transcripts from the three-week jury trial, including in particular the direct and cross-examination testimony of Dr. Ramesh Patel of Hargrove, Patel & Sullivan LLP, the government's forensic accounting expert.
(d) Financial records of Aurelia Pictures, Inc., including production budgets, bank account statements, general ledger records, and accounting records available through the court-appointed receivership. The receiver is Nathaniel W. Prescott of Ridgeway Advisory Group LLC, appointed on August 2, 2025, in California Film Commission v. Aurelia Pictures, Inc., Los Angeles Superior Court Case No. 25STCV08312.
(e) California Film Commission tax credit applications and all supporting documentation submitted in connection with the three productions at issue in the tax credit fraud counts.
(f) Investor agreements, subscription documents, private placement memoranda, and fund flow documentation for the productions involving Brindoval Investors Group LP and Lakeshore Capital Partners LLC.
(g) The government's restitution submissions, including the victim impact statements filed by Aldrich & McBride LLP on behalf of Brindoval Investors Group LP and any declarations or supporting documentation submitted by other identified victims.
(h) The defense's internal loss calculation analysis prepared by Lisa Morrow, Lead Associate, and Peter Vassiliev, Senior Associate, of Calderwood & Harkness LLP.
(i) Any additional documents, data, or materials as may be identified during the course of the engagement and deemed relevant to your analysis.
We anticipate that the initial set of materials will be delivered to you within five business days of the execution of this letter. Supplemental materials will be provided on a rolling basis as they become available or as the scope of your analysis dictates.
5. Compensation
Dr. Chandrasekaran will be compensated for her professional services in connection with this engagement as follows:
Hourly Rate. You will be compensated at the rate of $675.00 per hour for all professional services rendered, including but not limited to document review, data analysis, economic modeling, conferences with counsel (whether in person, by telephone, or by videoconference), report preparation, deposition or hearing preparation, and testimony at hearings or proceedings.
Travel Time. Time spent traveling in connection with this engagement will be billed at one-half of the standard hourly rate, i.e., $337.50 per hour.
Expenses. Reasonable out-of-pocket expenses incurred in connection with this engagement will be reimbursed at cost upon submission of receipts. Reimbursable expenses include, without limitation, travel costs (airfare, ground transportation, parking), lodging, meals incurred during travel, copying and printing charges, and the cost of research materials or databases accessed specifically for this engagement. Any single expense item exceeding $500.00 should be approved in advance by Lisa Morrow.
Invoicing. Invoices should be submitted on a monthly basis to Calderwood & Harkness LLP, to the attention of Lisa Morrow, at the firm's Los Angeles office address: 2029 Century Park East, Suite 3300, Los Angeles, California 90067. Each invoice should include a reasonably detailed description of the services performed, the date on which each service was performed, the time expended, and an itemization of any out-of-pocket expenses for which reimbursement is sought.
Payment Terms. Payment will be made within thirty (30) days of the firm's receipt of each invoice (net 30 days).
Retainer. An initial retainer in the amount of $10,000.00 is requested and should be deposited into your trust or operating account upon execution of this letter. The retainer will be held and applied against the final invoice or invoices rendered in connection with this engagement. If the total fees and expenses incurred are less than the retainer amount, the unused balance will be refunded promptly upon the conclusion of the engagement.
6. Confidentiality and Privilege
All materials provided to you in connection with this engagement, and all work product generated by you in connection with this engagement—including notes, drafts, memoranda, data analyses, spreadsheets, communications, and reports—are provided and prepared at the direction of counsel for Ms. Fonseca and are protected by the attorney-client privilege and the attorney work product doctrine. These protections are of paramount importance given the nature of the pending sentencing proceedings and the sensitivity of the underlying materials.
You shall not disclose any materials, communications, analysis, findings, opinions, or other information related to this engagement to any third party without the prior written consent of Calderwood & Harkness LLP. This prohibition extends to colleagues, research assistants, family members, and any other person not authorized by the firm to receive such information. To the extent you require the assistance of a research assistant or associate in performing your analysis, please discuss this with Lisa Morrow in advance so that appropriate confidentiality protections can be arranged.
In the event you are contacted by any government representative (including the U.S. Attorney's Office, the Federal Bureau of Investigation, the U.S. Probation Office, or any other law enforcement or regulatory agency), opposing counsel, any member of the media, or any other third party regarding this matter or your retention by the defense, you shall immediately notify Lisa Morrow or Conrad Ashby and shall not provide any information, documents, or materials without counsel's express authorization. This instruction applies regardless of the manner of contact—whether by telephone, email, letter, in-person visit, or otherwise.
You should be aware that, in the event you are designated as a testifying expert and called to provide testimony at the sentencing hearing or any evidentiary hearing, certain privilege protections may be waived as to your opinions and the bases and reasons therefor, as required by applicable rules of criminal procedure and evidence. Counsel will advise you well in advance of any such designation and will discuss with you the scope of any potential waiver so that you may prepare accordingly.
7. Independence and Objectivity
You are retained as an independent expert, and Calderwood & Harkness LLP expects you to render your honest, objective professional opinions based on your thorough and independent analysis of the available data and relevant economic principles. Your credibility as an expert is of the utmost importance to the defense, and it depends upon the integrity and objectivity of your analysis.
Calderwood & Harkness LLP does not seek to influence or dictate the substance of your opinions. If your analysis leads you to conclusions that differ from the defense's preliminary assessments, we expect you to communicate those conclusions candidly and promptly. The firm retains the sole right to determine whether and how to use your work product in the sentencing proceedings, including the decision whether to submit your report to the Court, whether to call you as a witness, and how to present your findings in the defense's submissions.
8. Conflicts of Interest
By executing this letter, you confirm that you have conducted a reasonable inquiry and have determined that you have no prior professional or personal relationship with any of the following individuals or entities that would impair your objectivity or create a conflict of interest in connection with this engagement:
(a) The prosecution team, including Assistant United States Attorney Brenda K. Tillotson and Assistant United States Attorney Derek R. Huang;
(b) The government's forensic accounting expert, Dr. Ramesh Patel, CPA, CFF, of Hargrove, Patel & Sullivan LLP;
(c) The sentencing judge, the Honorable Catherine M. Driscoll, United States District Judge;
(d) The United States Probation Officer assigned to this matter, Michael T. Brennan;
(e) Any of the identified victims, including Brindoval Investors Group LP, Lakeshore Capital Partners LLC, the California Film Commission, or any of the individual investors; and
(f) Counsel for any of the identified victims, including Susan R. Aldrich of Aldrich & McBride LLP.
You shall promptly notify Calderwood & Harkness LLP of any actual or potential conflicts of interest that may arise during the course of the engagement, including any new professional engagements, consulting arrangements, or personal relationships that could be perceived as impairing your independence or objectivity.
9. Term and Termination
This engagement shall commence upon your execution of this letter and shall continue through the completion of the sentencing proceedings in United States v. Marguerite D. Fonseca, currently scheduled for March 6, 2026. The engagement shall also encompass any post-sentencing matters for which your services may be reasonably required, including without limitation any proceedings related to restitution determinations, any resentencing proceedings, or any appellate proceedings in which your expert analysis may be relevant.
Either party may terminate this engagement upon fourteen (14) days' prior written notice to the other party. In the event of termination, you shall promptly return to Calderwood & Harkness LLP all materials provided to you in connection with this engagement, as well as all work product generated by you, including notes, drafts, data files, and analyses. Termination shall not affect any confidentiality or privilege obligations, which shall survive termination of the engagement indefinitely.
Calderwood & Harkness LLP will remain responsible for the payment of all fees and expenses properly incurred through the effective date of termination, in accordance with the compensation terms set forth in Section 5 above.
10. Acceptance and Counterparts
If the foregoing terms are acceptable to you, please indicate your acceptance by signing in the space provided below and returning a copy of this fully executed letter to Lisa Morrow at the firm's Los Angeles office address or by email to lmorrow@calderwoodharkness.com. We request that the signed letter be returned within ten (10) business days of your receipt.
This letter may be executed in counterparts, including by electronic signature (e.g., Brightwater Software or similar platforms), each of which shall be deemed an original and all of which together shall constitute one and the same instrument.
We are confident that your expertise in applied economics and financial loss analysis will be invaluable to the defense team as we work to ensure a just and fair outcome for Ms. Fonseca at sentencing. The issues presented in this case—particularly the double-counting errors and the failure to account for reinvested funds—are precisely the types of complex economic questions that require the rigorous, independent analysis that you are uniquely qualified to provide. We look forward to working with you on this important engagement and to a productive collaboration in the weeks ahead.
Please do not hesitate to contact Lisa Morrow at (310) 556-8214 or lmorrow@calderwoodharkness.com, or Conrad Ashby at (310) 556-8207 or cashby@calderwoodharkness.com, should you have any questions regarding this letter or the engagement.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Lisa Morrow Lead Associate, Banking & Finance Calderwood & Harkness LLP 2029 Century Park East, Suite 3300 Los Angeles, California 90067 Telephone: (310) 556-8214
Email: lmorrow@calderwoodharkness.com
Approved by:
________________________________________
Conrad Ashby Responsible Partner, White Collar Defense & Investigations Calderwood & Harkness LLP
AGREED AND ACCEPTED:
By executing below, Dr. Priya Chandrasekaran acknowledges that she has read, understood, and agrees to be bound by the terms and conditions set forth in this Expert Retention Letter.
________________________________________
Dr. Priya Chandrasekaran, Ph.D. Department of Economics Westbridge University
Date: ________
cc: Conrad Ashby, Calderwood & Harkness LLP Victoria Chambers, Calderwood & Harkness LLP Peter Vassiliev, Calderwood & Harkness LLP
Enclosures: (1) Conflict of Interest Disclosure Form (2) W-9 Request for Taxpayer Identification Number and Certification

CALDERWOOD & HARKNESS LLP Attorneys at Law

CALDERWOOD & HARKNESS LLP

AGREED AND ACCEPTED:

Record

Parties

Dates

Amounts