1035-00001 · Client 1035 · Expert Engagement

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

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PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT

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

November 25, 2025

Dr. Sandra Oleander, Ph.D. Lead Mitigation Specialist Thornfield Mitigation Consulting LLC 1520 Blake Street, Suite 400 Denver, CO 80202

Re: Retention of Thornfield Mitigation Consulting LLC — Sentencing Mitigation Services

Matter: United States v. Marguerite D. Fonseca, Case No. 2:24-cr-00583-CMD

Court: United States District Court for the Central District of California

Before: Hon. Catherine M. Driscoll, United States District Judge

Dear Dr. Oleander:

I write on behalf of Calderwood & Harkness LLP, counsel of record for Marguerite D. Fonseca, to formally retain Thornfield Mitigation Consulting LLC and you personally to prepare a comprehensive social history investigation and mitigation report for Ms. Fonseca in connection with her forthcoming federal sentencing. We have selected Thornfield based on your well-established reputation in the preparation of federal sentencing mitigation materials and your extensive experience in white-collar criminal matters. This letter sets forth the terms and conditions of the engagement.

As you are aware from our preliminary telephone conversation on November 19, 2025, Ms. Fonseca was convicted on September 18, 2025, following a three-week jury trial before the Honorable Catherine M. Driscoll, on four counts of wire fraud in violation of 18 U.S.C. § 1343 (Counts One through Four of the Superseding Indictment), two counts of money laundering in violation of 18 U.S.C. § 1956(a)(1)(B)(i) (Counts Five and Six), and one count of conspiracy to commit wire fraud in violation of 18 U.S.C. § 1371 (Count Seven). Ms. Fonseca was acquitted on two additional counts of wire fraud and one count of tax evasion. The sentencing hearing is currently scheduled for March 6, 2026, before Judge Driscoll.

The Presentence Investigation Report in this matter was disclosed to defense counsel on November 3, 2025, by Probation Officer Michael T. Brennan of the United States Probation Office for the Central District of California. The advisory United States Sentencing Guidelines range as calculated in the PSR is 108 to 135 months of imprisonment, based on a Total Offense Level of 31 and a Criminal History Category of I. It is the defense's intention to challenge certain aspects of this Guidelines calculation, including, among other things, the loss amount enhancement and the specific offense characteristics applied by the Probation Office. More importantly, the defense intends to seek a substantial below-Guidelines sentence pursuant to 18 U.S.C. § 3553(a), and the mitigation report you will prepare will be central to that effort.

Calderwood & Harkness was retained as sentencing counsel on November 12, 2025. Ms. Fonseca's prior trial counsel was Kerrigan & Wolfe LLP, with Harrison J. Kerrigan serving as lead trial attorney. Kerrigan & Wolfe has cooperated fully in the transition and has provided all trial materials and client files to our firm. We expect to continue to receive cooperation from prior counsel as needed during the course of your investigation.

1. Background on the Client

Marguerite Delphine Fonseca is fifty-two years old. She is the founder and former Chief Executive Officer of Aurelia Pictures, Inc., a California corporation (Secretary of State File No. C3276451) that was headquartered at 8950 West Sunset Boulevard, Suite 1400, West Hollywood, California 90069. Aurelia Pictures was an independent film and television production company that, over a fifteen-year period of operation, produced twenty-three feature films and six limited television series, generating cumulative gross revenues of approximately $312 million. The company employed, at its peak, over one hundred and fifty full-time staff and worked with thousands of independent contractors, actors, writers, and crew members. Its productions were distributed domestically and internationally and received numerous industry accolades, including multiple festival selections and award nominations.

Ms. Fonseca was born in Sacramento, California, to immigrant parents from the Philippines. Her father, Renato Fonseca, and her mother, Corazon Fonseca, emigrated to the United States in 1970 and settled in Sacramento's Del Paso Heights neighborhood, a community then characterized by significant economic disadvantage. Ms. Fonseca was the first in her family to attend college. She earned a Bachelor of Arts degree in Film & Digital Media from the University of California, Santa Cruz, in 1995, and a Master of Fine Arts degree in Film Production from the American Film Institute in 1998. Both degrees were obtained with the assistance of academic scholarships.

Ms. Fonseca has no prior criminal history of any kind. She has never previously been arrested, charged, indicted, or convicted of any offense, whether federal, state, or local, and her criminal history score under the Sentencing Guidelines is zero, placing her in Criminal History Category I.

Ms. Fonseca currently resides at 1847 Mulholland Terrace, Los Angeles, California 90068. She was released following trial on a $2.5 million secured bond, with conditions that include surrender of her passport, restriction of travel to the Central District of California, and regular reporting to the Pretrial Services Office. She has complied fully with all conditions of her release.

Ms. Fonseca is the mother of two minor children: Elena Fonseca, age seventeen, and Marco Fonseca, age fourteen. Both children reside with Ms. Fonseca at the Mulholland Terrace address. Ms. Fonseca was divorced from Alejandro Fonseca in 2019, and she is the primary custodial parent of both children. Mr. Fonseca resides outside the United States and has had limited involvement in the children's day-to-day care.

In addition, Ms. Fonseca is the primary caretaker of her elderly mother, Corazon Fonseca, age seventy-nine, who was diagnosed with early-stage Alzheimer's disease in 2024. Corazon Fonseca resides with the defendant at the Mulholland Terrace address and depends on Ms. Fonseca for her daily care, medication management, medical appointments, and supervision. No other family members reside in the Los Angeles area who are capable of assuming these caregiving responsibilities in Ms. Fonseca's absence.

2. Scope of Engagement / Services to Be Performed

The engagement of Thornfield Mitigation Consulting LLC and Dr. Sandra Oleander shall encompass the following services, each of which is described in greater detail below.

2.1 Social History Investigation

Dr. Oleander shall conduct a comprehensive biographical investigation of Ms. Fonseca's life history from birth to present. This investigation is intended to produce a thorough, accurate, and nuanced portrait of Ms. Fonseca's personal history and character, suitable for presentation to the Court at sentencing. The investigation shall include, but is not limited to, the following areas of inquiry:

(a) Family Background and Immigration History. Investigation of the immigration history of Ms. Fonseca's parents, Renato and Corazon Fonseca, from the Philippines to the United States, including the circumstances of their emigration, their experiences upon arrival, and the cultural and economic challenges they faced in establishing themselves in Sacramento's Del Paso Heights neighborhood. This inquiry shall explore the family's economic circumstances during Ms. Fonseca's childhood, including conditions of poverty, her father Renato Fonseca's experience working two simultaneous jobs to support the family, and her mother Corazon Fonseca's chronic illness during Ms. Fonseca's formative years.

(b) Childhood Caregiving Role. Investigation of Ms. Fonseca's assumption of significant caregiving responsibilities beginning at approximately age twelve, when her mother's chronic health conditions required Ms. Fonseca to take on a primary role in managing household duties and caring for younger family members. This investigation shall examine the impact of these responsibilities on Ms. Fonseca's social, emotional, and psychological development.

(c) Educational Trajectory. Documentation of Ms. Fonseca's educational history, including her academic achievements in secondary school, her receipt of scholarships to attend the University of California, Santa Cruz, and the American Film Institute, and the challenges she overcame as a first-generation college student from an economically disadvantaged background.

(d) Professional Career and Founding of Aurelia Pictures. Documentation of Ms. Fonseca's professional career in the film and entertainment industry, including her early career experiences, the founding and growth of Aurelia Pictures, Inc. (incorporated March 14, 2009), and the company's evolution into a recognized independent production entity. This portion of the investigation shall also document Ms. Fonseca's professional reputation, her contributions to the industry, and her role in promoting diversity and inclusion in independent filmmaking.

(e) Marriage and Divorce. Investigation of Ms. Fonseca's marriage to Alejandro Fonseca and their subsequent divorce in 2019, including the circumstances surrounding the dissolution of the marriage and its impact on Ms. Fonseca and her children.

(f) Death of Father. Investigation of the death of Ms. Fonseca's father, Renato Fonseca, in 2016, and the emotional, psychological, and practical impact of his passing on Ms. Fonseca, including its role as a potential contextual stressor during the period in which the charged conduct is alleged to have occurred.

2.2 Family Interviews

Dr. Oleander shall conduct in-person interviews with members of Ms. Fonseca's immediate family, extended family, friends, mentors, and professional associates. The following interviews are anticipated:

(a) Corazon Fonseca (Mother, Age 79). In-person interview with Ms. Fonseca's mother, Corazon Fonseca, who has been diagnosed with early-stage Alzheimer's disease. Dr. Oleander shall assess Corazon Fonseca's capacity to participate in an interview at the time the interview is conducted and shall employ appropriate interviewing protocols for individuals with cognitive impairment. To the extent Corazon Fonseca is able to provide reliable information regarding her daughter's childhood, family history, and character, such information shall be documented in the mitigation report.

(b) Elena Fonseca (Daughter, Age 17). In-person interview with Ms. Fonseca's daughter, Elena Fonseca, age seventeen. Dr. Oleander shall employ appropriate protocols for interviewing a minor, including obtaining informed consent from Ms. Fonseca as the custodial parent and conducting the interview in a manner that is sensitive to the minor's emotional well-being and developmental stage. The interview shall focus on the child's relationship with her mother, the impact of the proceedings on the family, and the role Ms. Fonseca plays as a parent and caretaker.

(c) Marco Fonseca (Son, Age 14). In-person interview with Ms. Fonseca's son, Marco Fonseca, age fourteen. The same protocols applicable to the interview of Elena Fonseca shall apply. Dr. Oleander shall exercise particular sensitivity given Marco's younger age and any emotional or psychological effects the prosecution and conviction may have had on him.

(d) Other Family Members, Friends, Mentors, and Community Members. Interviews with additional individuals identified during the course of the investigation who can provide relevant information regarding Ms. Fonseca's life history, character, and personal qualities. Counsel will provide a preliminary list of potential interviewees (enclosed herewith), and Dr. Oleander is authorized to identify additional interviewees as the investigation progresses, in consultation with counsel.

(e) Professional Colleagues and Associates. Interviews with colleagues and professional associates who can speak to Ms. Fonseca's character, work ethic, professional contributions, and reputation in the entertainment industry. These interviews may include individuals who worked with Ms. Fonseca at Aurelia Pictures, industry collaborators, and others who can provide context regarding Ms. Fonseca's professional life.

(f) Coordination with Character Letter Writers. Counsel anticipates soliciting character letters from approximately forty or more individuals, including industry colleagues, community members, and family. Dr. Oleander shall coordinate with these individuals to the extent directed by counsel, including providing guidance on the content and focus of character letters and, where appropriate, conducting brief interviews to supplement the letter writers' written submissions.

2.3 Records Review

Dr. Oleander shall review the following categories of records as part of the social history investigation:

(a) Educational Records. Records from the University of California, Santa Cruz, and the American Film Institute, including transcripts, scholarship records, admissions materials, and any other records relevant to documenting Ms. Fonseca's educational trajectory and achievements.

(b) Employment and Corporate Records. Employment and corporate records related to Aurelia Pictures, Inc., including incorporation documents, corporate governance records, employment agreements, and other records relevant to documenting Ms. Fonseca's founding and leadership of the company.

(c) Medical and Mental Health Records. Medical and mental health treatment records, with particular attention to records from Dr. Elaine Varma at Pacific Mind Health Associates, located at 1200 Wilshire Boulevard, Suite 300, Los Angeles, California 90017. These records document Ms. Fonseca's diagnoses of Major Depressive Disorder (first diagnosed in 2017) and Generalized Anxiety Disorder (first diagnosed in 2019), as well as her ongoing treatment with sertraline 100mg and weekly psychotherapy. Dr. Oleander shall review these records to understand the nature, onset, and course of Ms. Fonseca's mental health conditions and to contextualize them within the broader narrative of her life history and the circumstances of the offense.

(d) Financial Records. Relevant financial records as appropriate to the mitigation narrative, including records that document Ms. Fonseca's charitable giving, philanthropic activities, and financial support for family members. This review is limited to records relevant to mitigation and is not intended to duplicate the work of forensic accountants or other financial experts retained in this matter.

(e) Records of the Aurelia Foundation. Records relating to the Aurelia Foundation, a charitable organization established by Ms. Fonseca in 2014 for the purpose of supporting emerging filmmakers from underrepresented communities. The Foundation disbursed approximately $1.8 million in scholarships and grants between 2014 and 2023, and its activities are relevant to documenting Ms. Fonseca's commitment to philanthropy and community service.

(f) Community and Nonprofit Involvement Records. Records relating to Ms. Fonseca's involvement with the Filipino-American Arts Coalition ("FAAC"), through which she mentored over sixty young filmmakers, and the Los Angeles Youth Media Project ("LAYMP"), on whose board of directors she served from 2016 to 2023. These records are relevant to documenting the breadth and depth of Ms. Fonseca's community contributions.

Counsel will assist in obtaining these records through appropriate authorizations and releases, which Ms. Fonseca will execute as necessary. Dr. Oleander shall notify counsel promptly of any difficulty in obtaining records or any need for additional authorizations.

2.4 Preparation of Written Mitigation Report

Dr. Oleander shall prepare a comprehensive written mitigation report suitable for submission to the Court as an exhibit to the Defendant's Sentencing Memorandum. The report shall be a professional-quality document, thoroughly sourced and documented, that presents the results of the social history investigation in a clear, compelling, and organized manner.

The mitigation report shall address all relevant mitigation themes, including but not limited to the following:

(a) Personal History and Characteristics. A comprehensive account of Ms. Fonseca's personal history as a first-generation Filipino-American raised in poverty in Sacramento, California, including the sacrifices made by her immigrant parents, her early assumption of caregiving responsibilities, and the resilience and determination she demonstrated in overcoming significant obstacles to achieve academic and professional success.

(b) Mental Health History and Contextual Stressors. A discussion of Ms. Fonseca's mental health history, including her diagnoses of Major Depressive Disorder and Generalized Anxiety Disorder, and the contextual stressors that contributed to the onset and exacerbation of these conditions, including the death of her father, Renato Fonseca, in 2016, and her divorce from Alejandro Fonseca in 2019. This section shall contextualize Ms. Fonseca's mental health within the broader narrative of her life and, to the extent appropriate, within the circumstances surrounding the charged conduct.

(c) Caregiving Responsibilities. A detailed account of Ms. Fonseca's caregiving responsibilities, including her role as the sole caretaker of her mother, Corazon Fonseca, who has been diagnosed with early-stage Alzheimer's disease, and her role as the primary custodial parent of her two minor children, Elena (age 17) and Marco (age 14). This section shall document the absence of any other family members in the Los Angeles area who are capable of assuming these caregiving duties in Ms. Fonseca's absence and shall address the impact that a term of incarceration would have on Ms. Fonseca's dependents.

(d) Charitable and Community Contributions. A comprehensive account of Ms. Fonseca's charitable activities and community involvement, including the establishment and operation of the Aurelia Foundation, her mentorship of over sixty young filmmakers through the Filipino-American Arts Coalition, and her board service with the Los Angeles Youth Media Project from 2016 to 2023. This section shall document the tangible impact of Ms. Fonseca's contributions on the communities and individuals she has served.

(e) Aberrant Behavior and Lack of Prior Criminal History. A discussion of the aberrational nature of the conduct of conviction in the context of Ms. Fonseca's twenty-five-year career and life history, including the absence of any prior criminal history, prior allegations of fraud or dishonesty, or other indicia of a propensity toward criminal conduct. This section shall present the offense conduct as a departure from an otherwise law-abiding and productive life.

(f) Expression of Remorse, Cooperation, and Non-Dissipation of Assets. To the extent supported by the investigation, documentation of Ms. Fonseca's expression of genuine remorse for the harm caused by her conduct, her cooperation with the court-appointed receivership in the civil proceedings, and her non-dissipation of assets following the initiation of the criminal investigation.

The completed mitigation report shall be delivered to Calderwood & Harkness LLP no later than February 1, 2026, to allow sufficient time for review, revision, and incorporation into the Defendant's Sentencing Memorandum, which counsel anticipates filing on or about February 14, 2026. Dr. Oleander acknowledges that this deadline is critical to the defense timeline and agrees to make best efforts to complete the report by that date. In the event unforeseen circumstances arise that may impact the delivery date, Dr. Oleander shall notify counsel immediately so that appropriate adjustments can be made.

2.5 Coordination with Other Defense Experts

Dr. Oleander shall coordinate her investigation, as directed by counsel, with the work of other defense experts retained in this matter, as follows:

(a) Dr. Kenneth Whitmore, Forensic Psychiatrist. Dr. Kenneth Whitmore is a board-certified forensic psychiatrist with offices at 9401 Wilshire Boulevard, Suite 760, Beverly Hills, California 90212. Dr. Whitmore has been retained to conduct a comprehensive psychiatric evaluation of Ms. Fonseca, including diagnostic assessment, evaluation of cognitive and emotional functioning, and preparation of a forensic psychiatric report for submission to the Court. Dr. Oleander shall share relevant interview notes, background information, and records with Dr. Whitmore as directed by counsel, and shall coordinate with Dr. Whitmore to avoid duplication of effort and to ensure consistency in the presentation of information to the Court. All such communications and exchanges of information shall be made at the direction of and through counsel, and shall be subject to attorney work product protections.

(b) Dr. Priya Chandrasekaran, Economics Expert. Dr. Priya Chandrasekaran of Westbridge University has been retained as an economics expert to address issues related to loss calculation and financial impact. No direct coordination between Dr. Oleander and Dr. Chandrasekaran is anticipated at this time; however, Dr. Oleander shall remain available for consultation with Dr. Chandrasekaran if counsel determines that such coordination would be beneficial.

2.6 Testimony at Sentencing Hearing

Dr. Oleander shall be available to testify at the sentencing hearing currently scheduled for March 6, 2026, before the Honorable Catherine M. Driscoll, United States District Court for the Central District of California, located at 350 West 1st Street, Los Angeles, California 90012. If called to testify, Dr. Oleander's testimony may include, but is not limited to, the following:

(a) Presentation of the findings of the mitigation investigation, including a summary of Ms. Fonseca's social history and the themes identified in the written mitigation report;

(b) Expert opinion regarding Ms. Fonseca's social history and its relevance to sentencing, including the significance of the mitigating factors identified in the report;

(c) Responses to questions from the Court, defense counsel, and the government. The lead prosecutor in this matter is Assistant United States Attorney Brenda K. Tillotson, and co-counsel for the government is Assistant United States Attorney Derek R. Huang, both of the United States Attorney's Office for the Central District of California.

The decision on whether testimony by Dr. Oleander will be required at the sentencing hearing shall be made by Calderwood & Harkness LLP no later than February 21, 2026. Counsel will notify Dr. Oleander promptly of this decision so that she may make the necessary travel and scheduling arrangements. If the sentencing hearing is continued to a later date, Dr. Oleander shall make reasonable efforts to remain available for the rescheduled date.

3. Fees and Billing

The fees for the engagement described in this letter are as follows:

3.1 Flat Fee for Social History Investigation and Mitigation Report. Thornfield Mitigation Consulting LLC shall be paid a flat fee of Forty-Five Thousand Dollars ($45,000.00) for the performance of the social history investigation and the preparation of the written mitigation report as described in Section 2 of this letter. This flat fee is inclusive of all professional time expended by Dr. Oleander and any support staff at Thornfield in connection with the investigation and report, including all interviews, records review, research, drafting, and revision.

The flat fee shall be payable in two equal installments as follows:

(a) First Installment: Twenty-Two Thousand Five Hundred Dollars ($22,500.00), due and payable upon execution of this letter agreement; and

(b) Second Installment: Twenty-Two Thousand Five Hundred Dollars ($22,500.00), due and payable upon delivery of the completed mitigation report to Calderwood & Harkness LLP.

3.2 Testimony Fee. In the event Dr. Oleander is called to testify at the sentencing hearing or at any related evidentiary proceedings, Thornfield Mitigation Consulting LLC shall be paid a testimony fee of Six Thousand Five Hundred Dollars ($6,500.00) per day for each day on which Dr. Oleander provides testimony or is required to be present at the courthouse in connection with anticipated testimony. This fee covers preparation for testimony conducted on the day of the hearing as well as actual testimony time. The testimony fee shall be invoiced separately within fifteen (15) days following the date of testimony.

3.3 Travel and Out-of-Pocket Expenses. In addition to the fees set forth above, Calderwood & Harkness LLP shall reimburse Thornfield Mitigation Consulting LLC for all reasonable travel and out-of-pocket expenses incurred in connection with this engagement, including but not limited to airfare (coach class for domestic travel), lodging at reasonable rates, ground transportation, meals while traveling, and copying and printing costs. Based on the anticipated scope of travel required for this engagement — principally travel from Denver, Colorado, to Los Angeles, California, for in-person interviews and potential testimony — the estimated travel expenses are approximately $3,000 to $5,000. Thornfield shall submit expense reports with supporting documentation on a monthly basis, and Calderwood & Harkness shall process reimbursement within thirty (30) days of receipt.

3.4 Invoicing and Payment. All invoices for fees and expenses shall be directed to Calderwood & Harkness LLP at the address set forth in the letterhead of this letter, to the attention of Victoria Chambers, Billing Partner. Marguerite D. Fonseca, as the client, is the ultimate responsible party for all expert fees and expenses incurred in connection with this engagement unless otherwise arranged between Calderwood & Harkness LLP and Ms. Fonseca.

4. Confidentiality and Attorney Work Product

All work performed by Dr. Oleander and Thornfield Mitigation Consulting LLC under this engagement is undertaken at the direction of counsel and in connection with anticipated litigation (specifically, the sentencing proceedings in United States v. Fonseca). Accordingly, the work product generated in the course of this engagement, including but not limited to interview notes, draft reports, memoranda, analysis, and communications between Dr. Oleander and counsel, is protected by the attorney work product doctrine as set forth in Hickman v. Taylor, 329 U.S. 495 (1947), and Federal Rule of Civil Procedure 26(b)(3), and, to the extent applicable, by the attorney-client privilege.

Dr. Oleander and Thornfield shall not disclose any information obtained during the course of this investigation to any third party — including but not limited to the government, the Probation Office, the Court, the media, or any other person or entity — without the prior written consent of Calderwood & Harkness LLP. The sole exception to this obligation of confidentiality is that, if Dr. Oleander is called to testify at the sentencing hearing, information contained in the final mitigation report that is filed with the Court becomes part of the public court record and is no longer subject to confidentiality restrictions.

All notes, drafts, preliminary interview summaries, internal memoranda, and other working materials that are not included in the final mitigation report shall remain attorney work product and shall not be disclosed to any third party absent a court order. In the event the government seeks to compel the production of such materials, counsel shall be notified immediately so that appropriate objections and motions for protective orders may be filed.

Dr. Oleander and Thornfield shall maintain all documents, records, files, and electronic data related to this engagement in a secure manner consistent with applicable professional standards and best practices, including the use of encrypted electronic storage, password-protected files, and physical security measures for hard-copy documents. Access to engagement materials shall be limited to Dr. Oleander and those members of Thornfield's staff who are directly involved in the engagement and who have been informed of the confidential nature of the materials.

Upon conclusion of the engagement, all original documents provided by counsel to Dr. Oleander and Thornfield — including but not limited to the Presentence Investigation Report, the Indictment, and any other court documents — shall be returned to Calderwood & Harkness LLP. Copies of such documents shall be destroyed in a secure manner, and Dr. Oleander shall certify in writing that such destruction has been completed. Thornfield may retain a copy of the final mitigation report for its own records, subject to the ongoing confidentiality obligations set forth in this section.

5. Independence and Professional Standards

Dr. Oleander is retained as an independent consultant and is not an employee, agent, or partner of Calderwood & Harkness LLP. Nothing in this letter agreement shall be construed to create an employment relationship, partnership, joint venture, or agency relationship between Dr. Oleander or Thornfield and Calderwood & Harkness LLP.

Dr. Oleander's mitigation report and any testimony she may provide at the sentencing hearing shall reflect her independent professional judgment based upon the facts and circumstances uncovered during the course of the investigation. While counsel may provide direction regarding the scope and focus of the investigation, and while counsel retains the right to review, comment upon, and request revisions to draft reports, the ultimate professional opinions and conclusions expressed in the report and in testimony are those of Dr. Oleander alone.

Dr. Oleander's qualifications for this engagement are well established. She holds a Doctor of Philosophy degree in Clinical Psychology from the University of Denver, conferred in 2004. She has specialized in federal sentencing mitigation work for over two decades and has prepared in excess of 280 federal sentencing mitigation reports in cases spanning a wide range of federal criminal offenses, including white-collar fraud, narcotics, firearms, immigration, and violent crime offenses. Her reports have been submitted in federal courts across the country, and she has testified as a mitigation expert in numerous sentencing proceedings. Her curriculum vitae, which is on file with this firm, reflects her qualifications in detail.

Dr. Oleander shall comply with all applicable professional and ethical standards in the performance of her duties under this engagement, including the ethical standards promulgated by the American Psychological Association, the standards of the National Association of Sentencing Advocates, and any applicable rules of professional conduct governing expert witnesses in the United States District Court for the Central District of California.

6. Term and Termination

This engagement shall commence upon execution of this letter agreement by both parties and shall continue through the completion of the sentencing hearing currently scheduled for March 6, 2026, or any continuation thereof, and the completion of all services described in Section 2 of this letter, whichever is later.

Either party may terminate this engagement upon fourteen (14) calendar days' prior written notice to the other party. In the event of termination by either party, Thornfield Mitigation Consulting LLC shall be entitled to compensation for the portion of the flat fee that is commensurate with the work completed as of the effective date of termination, as determined in good faith by the parties, plus reimbursement for any expenses incurred and not yet reimbursed as of that date. If the first installment of the flat fee has been paid and the value of work completed at the time of termination is less than $22,500, Thornfield shall refund the difference to Calderwood & Harkness LLP within thirty (30) days of the effective date of termination.

Calderwood & Harkness LLP reserves the right to extend the term of this engagement in the event that the sentencing hearing is continued by the Court to a date later than March 6, 2026. In such event, counsel shall provide written notice to Dr. Oleander of the new sentencing date and shall discuss with Dr. Oleander any adjustments to the scope of work or fees that may be necessitated by the extension. Any such adjustments shall be memorialized in a written amendment to this letter agreement.

7. Points of Contact

The following individuals shall serve as the designated points of contact for communications relating to this engagement:

Calderwood & Harkness LLP:

Primary Contact: Conrad Ashby, Partner (Responsible Attorney) Calderwood & Harkness LLP 2029 Century Park East, Suite 3300 Los Angeles, CA 90067 Direct: (310) 556-8214

Email: cashby@calderwoodharkness.com

Billing Contact: Victoria Chambers, Partner (Billing Partner) Calderwood & Harkness LLP 2029 Century Park East, Suite 3300 Los Angeles, CA 90067 Direct: (310) 556-8219

Email: vchambers@calderwoodharkness.com

Associates: Lisa Morrow, Lead Associate, and Peter Vassiliev, Working Associate, may coordinate logistics, document production, and scheduling on behalf of the team. Their contact information is as follows:

Lisa Morrow: (310) 556-8237 / lmorrow@calderwoodharkness.com Peter Vassiliev: (310) 556-8241 / pvassiliev@calderwoodharkness.com

Thornfield Mitigation Consulting LLC:

Primary Contact: Dr. Sandra Oleander, Ph.D., Lead Mitigation Specialist Thornfield Mitigation Consulting LLC 1520 Blake Street, Suite 400 Denver, CO 80202 Direct: (720) 508-3310

Email: soleander@thornfieldmc.com

All substantive communications regarding the investigation, including the sharing of confidential information, work product, and privileged materials, shall be directed to or through the primary contacts identified above unless otherwise agreed in writing.

8. Acceptance and Execution

If the foregoing terms and conditions are acceptable to you, please indicate your acceptance by signing and dating this letter in the space provided below and returning an executed copy to my attention at the address set forth above or by email to cashby@calderwoodharkness.com. Upon execution by both parties, this letter, together with Calderwood & Harkness's standard expert engagement terms and conditions (enclosed herewith and incorporated by reference), shall constitute the entire agreement between the parties with respect to the engagement described herein.

We look forward to working with you on this important matter, Dr. Oleander. Ms. Fonseca's liberty and the well-being of her family are at stake, and we are confident that your expertise and diligence will make a meaningful contribution to the defense's presentation at sentencing. Please do not hesitate to contact me directly if you have any questions regarding the terms of this letter or any aspect of the engagement.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Conrad Ashby Partner

Date: ________

ACKNOWLEDGMENT AND ACCEPTANCE

I, Dr. Sandra Oleander, on behalf of myself and Thornfield Mitigation Consulting LLC, hereby acknowledge that I have read and understand the foregoing terms and conditions and agree to perform the services described herein in accordance with those terms. I further confirm that I have no conflicts of interest that would prevent me from undertaking this engagement and that I am available to meet the deadlines and obligations set forth in this letter.

THORNFIELD MITIGATION CONSULTING LLC

By: ________

Dr. Sandra Oleander, Ph.D. Lead Mitigation Specialist

Date: ________

Enclosures:

1. Copy of the Presentence Investigation Report (disclosed November 3, 2025, by Probation Officer Michael T. Brennan) — provided under seal and subject to the Protective Order entered by the Court; for Dr. Oleander's confidential use only in connection with this engagement

2. Copy of the Superseding Indictment (returned April 10, 2024)

3. Jury Verdict Form (September 18, 2025)

4. Preliminary List of Potential Interviewees and Contact Information

5. Calderwood & Harkness LLP Standard Expert Engagement Terms and Conditions (incorporated by reference)

cc: Marguerite D. Fonseca (client) Victoria Chambers, Calderwood & Harkness LLP Lisa Morrow, Calderwood & Harkness LLP

PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT
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
November 25, 2025
Dr. Sandra Oleander, Ph.D. Lead Mitigation Specialist Thornfield Mitigation Consulting LLC 1520 Blake Street, Suite 400 Denver, CO 80202
Re: Retention of Thornfield Mitigation Consulting LLC — Sentencing Mitigation Services
Matter: United States v. Marguerite D. Fonseca, Case No. 2:24-cr-00583-CMD
Court: United States District Court for the Central District of California
Before: Hon. Catherine M. Driscoll, United States District Judge
Dear Dr. Oleander:
I write on behalf of Calderwood & Harkness LLP, counsel of record for Marguerite D. Fonseca, to formally retain Thornfield Mitigation Consulting LLC and you personally to prepare a comprehensive social history investigation and mitigation report for Ms. Fonseca in connection with her forthcoming federal sentencing. We have selected Thornfield based on your well-established reputation in the preparation of federal sentencing mitigation materials and your extensive experience in white-collar criminal matters. This letter sets forth the terms and conditions of the engagement.
As you are aware from our preliminary telephone conversation on November 19, 2025, Ms. Fonseca was convicted on September 18, 2025, following a three-week jury trial before the Honorable Catherine M. Driscoll, on four counts of wire fraud in violation of 18 U.S.C. § 1343 (Counts One through Four of the Superseding Indictment), two counts of money laundering in violation of 18 U.S.C. § 1956(a)(1)(B)(i) (Counts Five and Six), and one count of conspiracy to commit wire fraud in violation of 18 U.S.C. § 1371 (Count Seven). Ms. Fonseca was acquitted on two additional counts of wire fraud and one count of tax evasion. The sentencing hearing is currently scheduled for March 6, 2026, before Judge Driscoll.
The Presentence Investigation Report in this matter was disclosed to defense counsel on November 3, 2025, by Probation Officer Michael T. Brennan of the United States Probation Office for the Central District of California. The advisory United States Sentencing Guidelines range as calculated in the PSR is 108 to 135 months of imprisonment, based on a Total Offense Level of 31 and a Criminal History Category of I. It is the defense's intention to challenge certain aspects of this Guidelines calculation, including, among other things, the loss amount enhancement and the specific offense characteristics applied by the Probation Office. More importantly, the defense intends to seek a substantial below-Guidelines sentence pursuant to 18 U.S.C. § 3553(a), and the mitigation report you will prepare will be central to that effort.
Calderwood & Harkness was retained as sentencing counsel on November 12, 2025. Ms. Fonseca's prior trial counsel was Kerrigan & Wolfe LLP, with Harrison J. Kerrigan serving as lead trial attorney. Kerrigan & Wolfe has cooperated fully in the transition and has provided all trial materials and client files to our firm. We expect to continue to receive cooperation from prior counsel as needed during the course of your investigation.
1. Background on the Client
Marguerite Delphine Fonseca is fifty-two years old. She is the founder and former Chief Executive Officer of Aurelia Pictures, Inc., a California corporation (Secretary of State File No. C3276451) that was headquartered at 8950 West Sunset Boulevard, Suite 1400, West Hollywood, California 90069. Aurelia Pictures was an independent film and television production company that, over a fifteen-year period of operation, produced twenty-three feature films and six limited television series, generating cumulative gross revenues of approximately $312 million. The company employed, at its peak, over one hundred and fifty full-time staff and worked with thousands of independent contractors, actors, writers, and crew members. Its productions were distributed domestically and internationally and received numerous industry accolades, including multiple festival selections and award nominations.
Ms. Fonseca was born in Sacramento, California, to immigrant parents from the Philippines. Her father, Renato Fonseca, and her mother, Corazon Fonseca, emigrated to the United States in 1970 and settled in Sacramento's Del Paso Heights neighborhood, a community then characterized by significant economic disadvantage. Ms. Fonseca was the first in her family to attend college. She earned a Bachelor of Arts degree in Film & Digital Media from the University of California, Santa Cruz, in 1995, and a Master of Fine Arts degree in Film Production from the American Film Institute in 1998. Both degrees were obtained with the assistance of academic scholarships.
Ms. Fonseca has no prior criminal history of any kind. She has never previously been arrested, charged, indicted, or convicted of any offense, whether federal, state, or local, and her criminal history score under the Sentencing Guidelines is zero, placing her in Criminal History Category I.
Ms. Fonseca currently resides at 1847 Mulholland Terrace, Los Angeles, California 90068. She was released following trial on a $2.5 million secured bond, with conditions that include surrender of her passport, restriction of travel to the Central District of California, and regular reporting to the Pretrial Services Office. She has complied fully with all conditions of her release.
Ms. Fonseca is the mother of two minor children: Elena Fonseca, age seventeen, and Marco Fonseca, age fourteen. Both children reside with Ms. Fonseca at the Mulholland Terrace address. Ms. Fonseca was divorced from Alejandro Fonseca in 2019, and she is the primary custodial parent of both children. Mr. Fonseca resides outside the United States and has had limited involvement in the children's day-to-day care.
In addition, Ms. Fonseca is the primary caretaker of her elderly mother, Corazon Fonseca, age seventy-nine, who was diagnosed with early-stage Alzheimer's disease in 2024. Corazon Fonseca resides with the defendant at the Mulholland Terrace address and depends on Ms. Fonseca for her daily care, medication management, medical appointments, and supervision. No other family members reside in the Los Angeles area who are capable of assuming these caregiving responsibilities in Ms. Fonseca's absence.
2. Scope of Engagement / Services to Be Performed
The engagement of Thornfield Mitigation Consulting LLC and Dr. Sandra Oleander shall encompass the following services, each of which is described in greater detail below.
2.1 Social History Investigation
Dr. Oleander shall conduct a comprehensive biographical investigation of Ms. Fonseca's life history from birth to present. This investigation is intended to produce a thorough, accurate, and nuanced portrait of Ms. Fonseca's personal history and character, suitable for presentation to the Court at sentencing. The investigation shall include, but is not limited to, the following areas of inquiry:
(a) Family Background and Immigration History. Investigation of the immigration history of Ms. Fonseca's parents, Renato and Corazon Fonseca, from the Philippines to the United States, including the circumstances of their emigration, their experiences upon arrival, and the cultural and economic challenges they faced in establishing themselves in Sacramento's Del Paso Heights neighborhood. This inquiry shall explore the family's economic circumstances during Ms. Fonseca's childhood, including conditions of poverty, her father Renato Fonseca's experience working two simultaneous jobs to support the family, and her mother Corazon Fonseca's chronic illness during Ms. Fonseca's formative years.
(b) Childhood Caregiving Role. Investigation of Ms. Fonseca's assumption of significant caregiving responsibilities beginning at approximately age twelve, when her mother's chronic health conditions required Ms. Fonseca to take on a primary role in managing household duties and caring for younger family members. This investigation shall examine the impact of these responsibilities on Ms. Fonseca's social, emotional, and psychological development.
(c) Educational Trajectory. Documentation of Ms. Fonseca's educational history, including her academic achievements in secondary school, her receipt of scholarships to attend the University of California, Santa Cruz, and the American Film Institute, and the challenges she overcame as a first-generation college student from an economically disadvantaged background.
(d) Professional Career and Founding of Aurelia Pictures. Documentation of Ms. Fonseca's professional career in the film and entertainment industry, including her early career experiences, the founding and growth of Aurelia Pictures, Inc. (incorporated March 14, 2009), and the company's evolution into a recognized independent production entity. This portion of the investigation shall also document Ms. Fonseca's professional reputation, her contributions to the industry, and her role in promoting diversity and inclusion in independent filmmaking.
(e) Marriage and Divorce. Investigation of Ms. Fonseca's marriage to Alejandro Fonseca and their subsequent divorce in 2019, including the circumstances surrounding the dissolution of the marriage and its impact on Ms. Fonseca and her children.
(f) Death of Father. Investigation of the death of Ms. Fonseca's father, Renato Fonseca, in 2016, and the emotional, psychological, and practical impact of his passing on Ms. Fonseca, including its role as a potential contextual stressor during the period in which the charged conduct is alleged to have occurred.
2.2 Family Interviews
Dr. Oleander shall conduct in-person interviews with members of Ms. Fonseca's immediate family, extended family, friends, mentors, and professional associates. The following interviews are anticipated:
(a) Corazon Fonseca (Mother, Age 79). In-person interview with Ms. Fonseca's mother, Corazon Fonseca, who has been diagnosed with early-stage Alzheimer's disease. Dr. Oleander shall assess Corazon Fonseca's capacity to participate in an interview at the time the interview is conducted and shall employ appropriate interviewing protocols for individuals with cognitive impairment. To the extent Corazon Fonseca is able to provide reliable information regarding her daughter's childhood, family history, and character, such information shall be documented in the mitigation report.
(b) Elena Fonseca (Daughter, Age 17). In-person interview with Ms. Fonseca's daughter, Elena Fonseca, age seventeen. Dr. Oleander shall employ appropriate protocols for interviewing a minor, including obtaining informed consent from Ms. Fonseca as the custodial parent and conducting the interview in a manner that is sensitive to the minor's emotional well-being and developmental stage. The interview shall focus on the child's relationship with her mother, the impact of the proceedings on the family, and the role Ms. Fonseca plays as a parent and caretaker.
(c) Marco Fonseca (Son, Age 14). In-person interview with Ms. Fonseca's son, Marco Fonseca, age fourteen. The same protocols applicable to the interview of Elena Fonseca shall apply. Dr. Oleander shall exercise particular sensitivity given Marco's younger age and any emotional or psychological effects the prosecution and conviction may have had on him.
(d) Other Family Members, Friends, Mentors, and Community Members. Interviews with additional individuals identified during the course of the investigation who can provide relevant information regarding Ms. Fonseca's life history, character, and personal qualities. Counsel will provide a preliminary list of potential interviewees (enclosed herewith), and Dr. Oleander is authorized to identify additional interviewees as the investigation progresses, in consultation with counsel.
(e) Professional Colleagues and Associates. Interviews with colleagues and professional associates who can speak to Ms. Fonseca's character, work ethic, professional contributions, and reputation in the entertainment industry. These interviews may include individuals who worked with Ms. Fonseca at Aurelia Pictures, industry collaborators, and others who can provide context regarding Ms. Fonseca's professional life.
(f) Coordination with Character Letter Writers. Counsel anticipates soliciting character letters from approximately forty or more individuals, including industry colleagues, community members, and family. Dr. Oleander shall coordinate with these individuals to the extent directed by counsel, including providing guidance on the content and focus of character letters and, where appropriate, conducting brief interviews to supplement the letter writers' written submissions.
2.3 Records Review
Dr. Oleander shall review the following categories of records as part of the social history investigation:
(a) Educational Records. Records from the University of California, Santa Cruz, and the American Film Institute, including transcripts, scholarship records, admissions materials, and any other records relevant to documenting Ms. Fonseca's educational trajectory and achievements.
(b) Employment and Corporate Records. Employment and corporate records related to Aurelia Pictures, Inc., including incorporation documents, corporate governance records, employment agreements, and other records relevant to documenting Ms. Fonseca's founding and leadership of the company.
(c) Medical and Mental Health Records. Medical and mental health treatment records, with particular attention to records from Dr. Elaine Varma at Pacific Mind Health Associates, located at 1200 Wilshire Boulevard, Suite 300, Los Angeles, California 90017. These records document Ms. Fonseca's diagnoses of Major Depressive Disorder (first diagnosed in 2017) and Generalized Anxiety Disorder (first diagnosed in 2019), as well as her ongoing treatment with sertraline 100mg and weekly psychotherapy. Dr. Oleander shall review these records to understand the nature, onset, and course of Ms. Fonseca's mental health conditions and to contextualize them within the broader narrative of her life history and the circumstances of the offense.
(d) Financial Records. Relevant financial records as appropriate to the mitigation narrative, including records that document Ms. Fonseca's charitable giving, philanthropic activities, and financial support for family members. This review is limited to records relevant to mitigation and is not intended to duplicate the work of forensic accountants or other financial experts retained in this matter.
(e) Records of the Aurelia Foundation. Records relating to the Aurelia Foundation, a charitable organization established by Ms. Fonseca in 2014 for the purpose of supporting emerging filmmakers from underrepresented communities. The Foundation disbursed approximately $1.8 million in scholarships and grants between 2014 and 2023, and its activities are relevant to documenting Ms. Fonseca's commitment to philanthropy and community service.
(f) Community and Nonprofit Involvement Records. Records relating to Ms. Fonseca's involvement with the Filipino-American Arts Coalition ("FAAC"), through which she mentored over sixty young filmmakers, and the Los Angeles Youth Media Project ("LAYMP"), on whose board of directors she served from 2016 to 2023. These records are relevant to documenting the breadth and depth of Ms. Fonseca's community contributions.
Counsel will assist in obtaining these records through appropriate authorizations and releases, which Ms. Fonseca will execute as necessary. Dr. Oleander shall notify counsel promptly of any difficulty in obtaining records or any need for additional authorizations.
2.4 Preparation of Written Mitigation Report
Dr. Oleander shall prepare a comprehensive written mitigation report suitable for submission to the Court as an exhibit to the Defendant's Sentencing Memorandum. The report shall be a professional-quality document, thoroughly sourced and documented, that presents the results of the social history investigation in a clear, compelling, and organized manner.
The mitigation report shall address all relevant mitigation themes, including but not limited to the following:
(a) Personal History and Characteristics. A comprehensive account of Ms. Fonseca's personal history as a first-generation Filipino-American raised in poverty in Sacramento, California, including the sacrifices made by her immigrant parents, her early assumption of caregiving responsibilities, and the resilience and determination she demonstrated in overcoming significant obstacles to achieve academic and professional success.
(b) Mental Health History and Contextual Stressors. A discussion of Ms. Fonseca's mental health history, including her diagnoses of Major Depressive Disorder and Generalized Anxiety Disorder, and the contextual stressors that contributed to the onset and exacerbation of these conditions, including the death of her father, Renato Fonseca, in 2016, and her divorce from Alejandro Fonseca in 2019. This section shall contextualize Ms. Fonseca's mental health within the broader narrative of her life and, to the extent appropriate, within the circumstances surrounding the charged conduct.
(c) Caregiving Responsibilities. A detailed account of Ms. Fonseca's caregiving responsibilities, including her role as the sole caretaker of her mother, Corazon Fonseca, who has been diagnosed with early-stage Alzheimer's disease, and her role as the primary custodial parent of her two minor children, Elena (age 17) and Marco (age 14). This section shall document the absence of any other family members in the Los Angeles area who are capable of assuming these caregiving duties in Ms. Fonseca's absence and shall address the impact that a term of incarceration would have on Ms. Fonseca's dependents.
(d) Charitable and Community Contributions. A comprehensive account of Ms. Fonseca's charitable activities and community involvement, including the establishment and operation of the Aurelia Foundation, her mentorship of over sixty young filmmakers through the Filipino-American Arts Coalition, and her board service with the Los Angeles Youth Media Project from 2016 to 2023. This section shall document the tangible impact of Ms. Fonseca's contributions on the communities and individuals she has served.
(e) Aberrant Behavior and Lack of Prior Criminal History. A discussion of the aberrational nature of the conduct of conviction in the context of Ms. Fonseca's twenty-five-year career and life history, including the absence of any prior criminal history, prior allegations of fraud or dishonesty, or other indicia of a propensity toward criminal conduct. This section shall present the offense conduct as a departure from an otherwise law-abiding and productive life.
(f) Expression of Remorse, Cooperation, and Non-Dissipation of Assets. To the extent supported by the investigation, documentation of Ms. Fonseca's expression of genuine remorse for the harm caused by her conduct, her cooperation with the court-appointed receivership in the civil proceedings, and her non-dissipation of assets following the initiation of the criminal investigation.
The completed mitigation report shall be delivered to Calderwood & Harkness LLP no later than February 1, 2026, to allow sufficient time for review, revision, and incorporation into the Defendant's Sentencing Memorandum, which counsel anticipates filing on or about February 14, 2026. Dr. Oleander acknowledges that this deadline is critical to the defense timeline and agrees to make best efforts to complete the report by that date. In the event unforeseen circumstances arise that may impact the delivery date, Dr. Oleander shall notify counsel immediately so that appropriate adjustments can be made.
2.5 Coordination with Other Defense Experts
Dr. Oleander shall coordinate her investigation, as directed by counsel, with the work of other defense experts retained in this matter, as follows:
(a) Dr. Kenneth Whitmore, Forensic Psychiatrist. Dr. Kenneth Whitmore is a board-certified forensic psychiatrist with offices at 9401 Wilshire Boulevard, Suite 760, Beverly Hills, California 90212. Dr. Whitmore has been retained to conduct a comprehensive psychiatric evaluation of Ms. Fonseca, including diagnostic assessment, evaluation of cognitive and emotional functioning, and preparation of a forensic psychiatric report for submission to the Court. Dr. Oleander shall share relevant interview notes, background information, and records with Dr. Whitmore as directed by counsel, and shall coordinate with Dr. Whitmore to avoid duplication of effort and to ensure consistency in the presentation of information to the Court. All such communications and exchanges of information shall be made at the direction of and through counsel, and shall be subject to attorney work product protections.
(b) Dr. Priya Chandrasekaran, Economics Expert. Dr. Priya Chandrasekaran of Westbridge University has been retained as an economics expert to address issues related to loss calculation and financial impact. No direct coordination between Dr. Oleander and Dr. Chandrasekaran is anticipated at this time; however, Dr. Oleander shall remain available for consultation with Dr. Chandrasekaran if counsel determines that such coordination would be beneficial.
2.6 Testimony at Sentencing Hearing
Dr. Oleander shall be available to testify at the sentencing hearing currently scheduled for March 6, 2026, before the Honorable Catherine M. Driscoll, United States District Court for the Central District of California, located at 350 West 1st Street, Los Angeles, California 90012. If called to testify, Dr. Oleander's testimony may include, but is not limited to, the following:
(a) Presentation of the findings of the mitigation investigation, including a summary of Ms. Fonseca's social history and the themes identified in the written mitigation report;
(b) Expert opinion regarding Ms. Fonseca's social history and its relevance to sentencing, including the significance of the mitigating factors identified in the report;
(c) Responses to questions from the Court, defense counsel, and the government. The lead prosecutor in this matter is Assistant United States Attorney Brenda K. Tillotson, and co-counsel for the government is Assistant United States Attorney Derek R. Huang, both of the United States Attorney's Office for the Central District of California.
The decision on whether testimony by Dr. Oleander will be required at the sentencing hearing shall be made by Calderwood & Harkness LLP no later than February 21, 2026. Counsel will notify Dr. Oleander promptly of this decision so that she may make the necessary travel and scheduling arrangements. If the sentencing hearing is continued to a later date, Dr. Oleander shall make reasonable efforts to remain available for the rescheduled date.
3. Fees and Billing
The fees for the engagement described in this letter are as follows:
3.1 Flat Fee for Social History Investigation and Mitigation Report. Thornfield Mitigation Consulting LLC shall be paid a flat fee of Forty-Five Thousand Dollars ($45,000.00) for the performance of the social history investigation and the preparation of the written mitigation report as described in Section 2 of this letter. This flat fee is inclusive of all professional time expended by Dr. Oleander and any support staff at Thornfield in connection with the investigation and report, including all interviews, records review, research, drafting, and revision.
The flat fee shall be payable in two equal installments as follows:
(a) First Installment: Twenty-Two Thousand Five Hundred Dollars ($22,500.00), due and payable upon execution of this letter agreement; and
(b) Second Installment: Twenty-Two Thousand Five Hundred Dollars ($22,500.00), due and payable upon delivery of the completed mitigation report to Calderwood & Harkness LLP.
3.2 Testimony Fee. In the event Dr. Oleander is called to testify at the sentencing hearing or at any related evidentiary proceedings, Thornfield Mitigation Consulting LLC shall be paid a testimony fee of Six Thousand Five Hundred Dollars ($6,500.00) per day for each day on which Dr. Oleander provides testimony or is required to be present at the courthouse in connection with anticipated testimony. This fee covers preparation for testimony conducted on the day of the hearing as well as actual testimony time. The testimony fee shall be invoiced separately within fifteen (15) days following the date of testimony.
3.3 Travel and Out-of-Pocket Expenses. In addition to the fees set forth above, Calderwood & Harkness LLP shall reimburse Thornfield Mitigation Consulting LLC for all reasonable travel and out-of-pocket expenses incurred in connection with this engagement, including but not limited to airfare (coach class for domestic travel), lodging at reasonable rates, ground transportation, meals while traveling, and copying and printing costs. Based on the anticipated scope of travel required for this engagement — principally travel from Denver, Colorado, to Los Angeles, California, for in-person interviews and potential testimony — the estimated travel expenses are approximately $3,000 to $5,000. Thornfield shall submit expense reports with supporting documentation on a monthly basis, and Calderwood & Harkness shall process reimbursement within thirty (30) days of receipt.
3.4 Invoicing and Payment. All invoices for fees and expenses shall be directed to Calderwood & Harkness LLP at the address set forth in the letterhead of this letter, to the attention of Victoria Chambers, Billing Partner. Marguerite D. Fonseca, as the client, is the ultimate responsible party for all expert fees and expenses incurred in connection with this engagement unless otherwise arranged between Calderwood & Harkness LLP and Ms. Fonseca.
4. Confidentiality and Attorney Work Product
All work performed by Dr. Oleander and Thornfield Mitigation Consulting LLC under this engagement is undertaken at the direction of counsel and in connection with anticipated litigation (specifically, the sentencing proceedings in United States v. Fonseca). Accordingly, the work product generated in the course of this engagement, including but not limited to interview notes, draft reports, memoranda, analysis, and communications between Dr. Oleander and counsel, is protected by the attorney work product doctrine as set forth in Hickman v. Taylor, 329 U.S. 495 (1947), and Federal Rule of Civil Procedure 26(b)(3), and, to the extent applicable, by the attorney-client privilege.
Dr. Oleander and Thornfield shall not disclose any information obtained during the course of this investigation to any third party — including but not limited to the government, the Probation Office, the Court, the media, or any other person or entity — without the prior written consent of Calderwood & Harkness LLP. The sole exception to this obligation of confidentiality is that, if Dr. Oleander is called to testify at the sentencing hearing, information contained in the final mitigation report that is filed with the Court becomes part of the public court record and is no longer subject to confidentiality restrictions.
All notes, drafts, preliminary interview summaries, internal memoranda, and other working materials that are not included in the final mitigation report shall remain attorney work product and shall not be disclosed to any third party absent a court order. In the event the government seeks to compel the production of such materials, counsel shall be notified immediately so that appropriate objections and motions for protective orders may be filed.
Dr. Oleander and Thornfield shall maintain all documents, records, files, and electronic data related to this engagement in a secure manner consistent with applicable professional standards and best practices, including the use of encrypted electronic storage, password-protected files, and physical security measures for hard-copy documents. Access to engagement materials shall be limited to Dr. Oleander and those members of Thornfield's staff who are directly involved in the engagement and who have been informed of the confidential nature of the materials.
Upon conclusion of the engagement, all original documents provided by counsel to Dr. Oleander and Thornfield — including but not limited to the Presentence Investigation Report, the Indictment, and any other court documents — shall be returned to Calderwood & Harkness LLP. Copies of such documents shall be destroyed in a secure manner, and Dr. Oleander shall certify in writing that such destruction has been completed. Thornfield may retain a copy of the final mitigation report for its own records, subject to the ongoing confidentiality obligations set forth in this section.
5. Independence and Professional Standards
Dr. Oleander is retained as an independent consultant and is not an employee, agent, or partner of Calderwood & Harkness LLP. Nothing in this letter agreement shall be construed to create an employment relationship, partnership, joint venture, or agency relationship between Dr. Oleander or Thornfield and Calderwood & Harkness LLP.
Dr. Oleander's mitigation report and any testimony she may provide at the sentencing hearing shall reflect her independent professional judgment based upon the facts and circumstances uncovered during the course of the investigation. While counsel may provide direction regarding the scope and focus of the investigation, and while counsel retains the right to review, comment upon, and request revisions to draft reports, the ultimate professional opinions and conclusions expressed in the report and in testimony are those of Dr. Oleander alone.
Dr. Oleander's qualifications for this engagement are well established. She holds a Doctor of Philosophy degree in Clinical Psychology from the University of Denver, conferred in 2004. She has specialized in federal sentencing mitigation work for over two decades and has prepared in excess of 280 federal sentencing mitigation reports in cases spanning a wide range of federal criminal offenses, including white-collar fraud, narcotics, firearms, immigration, and violent crime offenses. Her reports have been submitted in federal courts across the country, and she has testified as a mitigation expert in numerous sentencing proceedings. Her curriculum vitae, which is on file with this firm, reflects her qualifications in detail.
Dr. Oleander shall comply with all applicable professional and ethical standards in the performance of her duties under this engagement, including the ethical standards promulgated by the American Psychological Association, the standards of the National Association of Sentencing Advocates, and any applicable rules of professional conduct governing expert witnesses in the United States District Court for the Central District of California.
6. Term and Termination
This engagement shall commence upon execution of this letter agreement by both parties and shall continue through the completion of the sentencing hearing currently scheduled for March 6, 2026, or any continuation thereof, and the completion of all services described in Section 2 of this letter, whichever is later.
Either party may terminate this engagement upon fourteen (14) calendar days' prior written notice to the other party. In the event of termination by either party, Thornfield Mitigation Consulting LLC shall be entitled to compensation for the portion of the flat fee that is commensurate with the work completed as of the effective date of termination, as determined in good faith by the parties, plus reimbursement for any expenses incurred and not yet reimbursed as of that date. If the first installment of the flat fee has been paid and the value of work completed at the time of termination is less than $22,500, Thornfield shall refund the difference to Calderwood & Harkness LLP within thirty (30) days of the effective date of termination.
Calderwood & Harkness LLP reserves the right to extend the term of this engagement in the event that the sentencing hearing is continued by the Court to a date later than March 6, 2026. In such event, counsel shall provide written notice to Dr. Oleander of the new sentencing date and shall discuss with Dr. Oleander any adjustments to the scope of work or fees that may be necessitated by the extension. Any such adjustments shall be memorialized in a written amendment to this letter agreement.
7. Points of Contact
The following individuals shall serve as the designated points of contact for communications relating to this engagement:
Calderwood & Harkness LLP:
Primary Contact: Conrad Ashby, Partner (Responsible Attorney) Calderwood & Harkness LLP 2029 Century Park East, Suite 3300 Los Angeles, CA 90067 Direct: (310) 556-8214
Email: cashby@calderwoodharkness.com
Billing Contact: Victoria Chambers, Partner (Billing Partner) Calderwood & Harkness LLP 2029 Century Park East, Suite 3300 Los Angeles, CA 90067 Direct: (310) 556-8219
Email: vchambers@calderwoodharkness.com
Associates: Lisa Morrow, Lead Associate, and Peter Vassiliev, Working Associate, may coordinate logistics, document production, and scheduling on behalf of the team. Their contact information is as follows:
Lisa Morrow: (310) 556-8237 / lmorrow@calderwoodharkness.com Peter Vassiliev: (310) 556-8241 / pvassiliev@calderwoodharkness.com
Thornfield Mitigation Consulting LLC:
Primary Contact: Dr. Sandra Oleander, Ph.D., Lead Mitigation Specialist Thornfield Mitigation Consulting LLC 1520 Blake Street, Suite 400 Denver, CO 80202 Direct: (720) 508-3310
Email: soleander@thornfieldmc.com
All substantive communications regarding the investigation, including the sharing of confidential information, work product, and privileged materials, shall be directed to or through the primary contacts identified above unless otherwise agreed in writing.
8. Acceptance and Execution
If the foregoing terms and conditions are acceptable to you, please indicate your acceptance by signing and dating this letter in the space provided below and returning an executed copy to my attention at the address set forth above or by email to cashby@calderwoodharkness.com. Upon execution by both parties, this letter, together with Calderwood & Harkness's standard expert engagement terms and conditions (enclosed herewith and incorporated by reference), shall constitute the entire agreement between the parties with respect to the engagement described herein.
We look forward to working with you on this important matter, Dr. Oleander. Ms. Fonseca's liberty and the well-being of her family are at stake, and we are confident that your expertise and diligence will make a meaningful contribution to the defense's presentation at sentencing. Please do not hesitate to contact me directly if you have any questions regarding the terms of this letter or any aspect of the engagement.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Conrad Ashby Partner
Date: ________
ACKNOWLEDGMENT AND ACCEPTANCE
I, Dr. Sandra Oleander, on behalf of myself and Thornfield Mitigation Consulting LLC, hereby acknowledge that I have read and understand the foregoing terms and conditions and agree to perform the services described herein in accordance with those terms. I further confirm that I have no conflicts of interest that would prevent me from undertaking this engagement and that I am available to meet the deadlines and obligations set forth in this letter.
THORNFIELD MITIGATION CONSULTING LLC
By: ________
Dr. Sandra Oleander, Ph.D. Lead Mitigation Specialist
Date: ________
Enclosures:
1.  Copy of the Presentence Investigation Report (disclosed November 3, 2025, by Probation Officer Michael T. Brennan) — provided under seal and subject to the Protective Order entered by the Court; for Dr. Oleander's confidential use only in connection with this engagement
2.  Copy of the Superseding Indictment (returned April 10, 2024)
3.  Jury Verdict Form (September 18, 2025)
4.  Preliminary List of Potential Interviewees and Contact Information
5.  Calderwood & Harkness LLP Standard Expert Engagement Terms and Conditions (incorporated by reference)
cc: Marguerite D. Fonseca (client) Victoria Chambers, Calderwood & Harkness LLP Lisa Morrow, Calderwood & Harkness LLP

PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT

CALDERWOOD & HARKNESS LLP

ACKNOWLEDGMENT AND ACCEPTANCE

THORNFIELD MITIGATION CONSULTING LLC

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