1035-00002 · Calderwood & Harkness LLP · Mediation & Negotiation

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CONFIDENTIAL

CALDERWOOD & HARKNESS LLP Attorneys at Law

777 South Flower Street, Suite 3400 Los Angeles, California 90017

Telephone: (213) 555-7200 Facsimile: (213) 555-7201 www.calderwoodharkness.com

October 20, 2023

Hon. Constance M. Yee (Ret.) c/o Pacific Coast Dispute Resolution Services 801 South Figueroa Street, Suite 1250 Los Angeles, California 90017

Re: Mediation Scheduling — In re Fonseca / Medrano Custody & Parenting Plan Case No.: 22STFL09847, Superior Court of California, County of Los Angeles C&H Matter No.: 1035-00002

Dear Judge Yee:

I write on behalf of Calderwood & Harkness LLP, counsel of record for Marguerite D. Fonseca (Petitioner) in the above-referenced custody and parenting-plan matter. The purpose of this letter is to respectfully request the scheduling of mediation sessions before Your Honor and to provide the background information we believe will be helpful in facilitating the process. As set forth in greater detail below, the parties have reached a point in the proceedings at which private mediation represents the most constructive path toward resolution of the outstanding custody, visitation, and child-support issues.

By way of brief procedural background, this matter arises from the dissolution of a registered domestic partnership between Ms. Fonseca and Rafael J. Medrano (Respondent). A judgment of dissolution was entered on November 3, 2022, in Case No. 22STFL09847, in the Superior Court of California, County of Los Angeles, Department 56. Pursuant to the terms of that judgment, the court expressly reserved jurisdiction over all issues pertaining to legal and physical custody, visitation and timeshare, and child support. Those reserved issues are now ripe for resolution, and both parties have expressed a strong desire to resolve them through mediation rather than contested litigation, in the interest of minimizing the emotional toll on their young children and preserving a cooperative co-parenting relationship going forward.

Nature of the Dispute

The parties, Marguerite D. Fonseca and Rafael J. Medrano, are the parents of two minor children:

1. Isabela Luz Fonseca-Medrano, born February 11, 2017 (currently age 6); and

2. Mateo Elías Fonseca-Medrano, born August 29, 2019 (currently age 4).

Ms. Fonseca and Mr. Medrano were registered domestic partners in the State of California from September 12, 2015, until the dissolution of the partnership was finalized by entry of judgment on November 3, 2022. Both children were born during the course of the partnership, and there is no dispute as to parentage. As noted above, the dissolution judgment specifically reserved jurisdiction over custody, visitation, and child support, as those issues were not resolved at the time the judgment was entered.

On May 2, 2023, Ms. Fonseca filed a Request for Order (RFO) seeking primary legal and physical custody of both minor children, together with guideline child support. The matter came before the Honorable Marcus T. Reyes, sitting in Department 56, for a hearing on May 30, 2023, at which time the court entered a temporary custody order establishing a 60/40 timeshare arrangement in favor of Ms. Fonseca for the pendency of the matter. That temporary order remains in effect as of the date of this letter.

On June 22, 2023, the court appointed Minor's Counsel, Tessa L. Brannigan, Esq., to represent the interests of both minor children in these proceedings, pursuant to California Family Code Section 3150. Ms. Brannigan has been actively involved in the matter since her appointment and has had the opportunity to meet with both children, both parents, and each party's counsel.

By stipulation filed with the court on July 14, 2023, the parties agreed to the appointment of a custody evaluator, Dr. Elena V. Sorensen, Psy.D., of Sorensen Family Behavioral Health, P.C., to conduct a comprehensive child custody evaluation under Evidence Code Section 730. Dr. Sorensen's evaluation included individual interviews with both parents, collateral interviews, home visits to each parent's residence, psychological testing, and direct observation of each parent's interaction with the children. Dr. Sorensen completed her evaluation and delivered her written report to all counsel and to the court on October 6, 2023. The report and its recommendations will, of course, form an important part of the mediation discussions.

With the custody evaluation now complete, both parties are prepared to engage in good-faith mediation to attempt to resolve all outstanding custody, parenting-plan, and child-support issues without the necessity of a contested hearing. Both counsel have conferred and are in agreement that mediation before Your Honor represents the best opportunity to achieve a comprehensive and durable resolution that serves the best interests of the children.

We note for the record that the court file in this matter has been sealed pursuant to California Rules of Court, Rule 2.550 et seq. The sealing order was entered in recognition of the public-facing nature of both parties' careers in the entertainment industry and, most importantly, the paramount privacy interests of the minor children. Accordingly, we respectfully request that all communications, briefs, and materials exchanged in connection with the mediation be treated with the highest degree of confidentiality, consistent with the court's sealing order and the protections afforded to mediation communications under Evidence Code Sections 1115 through 1128.

Issues for Mediation

We anticipate that the mediation will encompass the following issues, each of which remains unresolved between the parties:

1. Legal and Physical Custody. The parties seek to reach agreement on the allocation of legal custody (sole or joint) and physical custody (sole or joint, with a primary custodial parent designation, if appropriate) for both Isabela and Mateo.

2. Timeshare and Visitation Schedule. The parties need to establish a comprehensive timeshare and visitation schedule addressing the regular school-year schedule, summer vacation periods, and all major holidays and school breaks. The schedule should account for the children's ages, developmental needs, and current school enrollment.

3. Child Support. The parties intend to address the calculation of child support, including whether any deviation from the California guideline amount is warranted under the circumstances of this case, taking into account each parent's income, the agreed-upon timeshare, and the statutory factors set forth in Family Code Sections 4053 through 4057.

4. Education Costs. Both children are currently enrolled at Ridgeview Academy, a private school located in Sherman Oaks, California. The parties will need to address the allocation of tuition, fees, and related educational expenses between them, as well as a decision-making framework for future educational decisions.

5. Extracurricular Activity Costs. The parties seek to agree upon a methodology for the allocation of costs associated with the children's extracurricular activities, including enrollment fees, equipment, travel for competitions or performances, and related expenses.

6. Healthcare Cost-Sharing. The parties will address the allocation of uninsured and unreimbursed healthcare expenses for the children, including medical, dental, orthodontic, vision, and mental health costs, consistent with Family Code Section 4062.

7. Travel and On-Location Work Provisions. Both parents are employed in the entertainment industry. Mr. Medrano works as a freelance cinematographer, and his professional obligations require periodic travel to out-of-state filming locations for extended periods. The parenting plan will need to address travel notice requirements, make-up time provisions, and protocols for maintaining the children's contact with the traveling parent during periods of absence.

8. Parenting Plan Coordinator. The parties wish to discuss the appointment of a parenting plan coordinator to assist in the implementation and ongoing management of the parenting plan, including the resolution of day-to-day scheduling disputes and the interpretation of plan provisions.

9. Confidentiality and Non-Disparagement Provisions. Given the parties' public profiles and the court's sealing order, the parenting plan should include robust confidentiality provisions restricting each party's public disclosure of custody arrangements, as well as mutual non-disparagement provisions to protect the children's emotional well-being.

We recognize that additional issues may arise during the course of mediation, and we are prepared to address any matters that Your Honor believes would benefit from discussion in this forum.

Identification of Counsel and Participants

For Your Honor's reference and to facilitate coordination, we provide the following identification of all counsel and participants who will be involved in the mediation:

Petitioner's Counsel — Calderwood & Harkness LLP:

Priya Anand, Partner (Billing Partner) Devon Archer, Associate (Lead Associate; Primary Contact for Scheduling and Mediation Logistics)

Calderwood & Harkness LLP 777 South Flower Street, Suite 3400 Los Angeles, California 90017

Devon Archer Direct Telephone: (213) 555-7218 Devon Archer Email: d.archer@calderwoodharkness.com

Respondent's Counsel — Kwan, Delacroix & Samuels LLP:

Gwendolyn R. Kwan, Partner, Lead Counsel for Respondent (CA State Bar No. 218453) Benjamin T. Okafor, Associate (CA State Bar No. 312776)

Kwan, Delacroix & Samuels LLP 4400 Riverside Drive, Suite 700 Burbank, California 91505

Minor's Counsel:

Tessa L. Brannigan, Esq. (CA State Bar No. 267894) Law Offices of Tessa L. Brannigan 6320 Canoga Avenue, Suite 1500 Woodland Hills, California 91367

Ms. Brannigan was appointed by the court on June 22, 2023, pursuant to Family Code Section 3150, and represents the interests of both minor children. We respectfully request that Ms. Brannigan be included in all mediation-related communications, scheduling correspondence, and sessions, as her participation is essential to ensuring that the children's interests are fully represented throughout the process.

Both parties — Marguerite D. Fonseca and Rafael J. Medrano — will attend the mediation sessions in person.

Scheduling Request and Availability

We respectfully request that an initial mediation session be scheduled at the earliest mutually available date, with the goal of commencing mediation in mid-to-late November 2023. Counsel for both parties have conferred regarding availability, and we are pleased to report that both sides are generally available during the weeks of November 13, 2023, and November 20, 2023, for the first session. We respectfully request that Your Honor's office coordinate directly with all counsel of record and Minor's Counsel to confirm a specific date and time.

Based on the number and complexity of the issues outlined above, we anticipate that the matter may require two to three mediation sessions to reach a comprehensive resolution. We respectfully request that, following the initial session, subsequent sessions be scheduled approximately three to four weeks apart to allow sufficient time for the parties and their counsel to evaluate proposals, gather any additional information that may be requested, and prepare counterproposals between sessions.

Both parties have expressed a preference for full-day sessions, running from approximately 9:00 a.m. to 5:00 p.m., to allow adequate time for thorough discussion of all issues. We further request that the sessions be held at the offices of Pacific Coast Dispute Resolution Services, located at 801 South Figueroa Street, Suite 1250, Los Angeles, California 90017, unless Your Honor's office suggests an alternative venue.

Confidentiality

As noted above, the court file in this matter has been sealed pursuant to California Rules of Court, Rule 2.550 et seq. We wish to emphasize that all mediation communications, briefs, memoranda, correspondence, and other materials exchanged in connection with the mediation should be treated as strictly confidential, consistent with the court's sealing order and the statutory protections afforded to mediation communications under Evidence Code Sections 1115 through 1128.

The parties understand that they will be required to submit confidential mediation briefs in advance of each session, in accordance with Your Honor's standard protocol. We respectfully request confirmation of Your Honor's preferred timing for receipt of those briefs — for example, whether they should be submitted five business days or one full calendar week prior to each scheduled session — so that counsel may plan accordingly.

Mediation Fee Arrangements

We respectfully request confirmation of Your Honor's current mediation fee schedule, as administered through Pacific Coast Dispute Resolution Services, including the hourly or daily rate, any required retainer or deposit, and the cancellation policy.

The parties have agreed to split all mediation fees equally, on a 50/50 basis. We request that invoices be directed separately to counsel for each party, as follows:

• Petitioner's share: Calderwood & Harkness LLP, 777 South Flower Street, Suite 3400, Los Angeles, California 90017, Attention: Devon Archer, C&H Matter No. 1035-00002.

• Respondent's share: Kwan, Delacroix & Samuels LLP, 4400 Riverside Drive, Suite 700, Burbank, California 91505, Attention: Gwendolyn R. Kwan.

Closing

We wish to express our sincere appreciation for Your Honor's willingness to serve as mediator in this matter. Your Honor's extensive experience on the bench and widely recognized expertise in high-asset family law matters give both parties considerable confidence that the mediation process will be conducted with the care, sensitivity, and thoroughness that the circumstances of this case require. Both Ms. Fonseca and Mr. Medrano share a genuine commitment to reaching a resolution that serves the best interests of Isabela and Mateo, and they believe that Your Honor's involvement will greatly facilitate that goal.

Should Your Honor require any additional information, documentation, or preliminary submissions in advance of the first mediation session, we are prepared to provide such materials promptly upon request. We would be grateful if scheduling could be coordinated at Your Honor's earliest convenience so that the parties may proceed without unnecessary delay.

All scheduling communications may be directed to the undersigned at the contact information provided below. I am available at your convenience and will endeavor to respond to any inquiries within one business day.

Thank you for your time and attention to this matter. We look forward to working with Your Honor toward a resolution that protects the well-being of both children.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Devon Archer Associate 777 South Flower Street, Suite 3400 Los Angeles, California 90017 Telephone: (213) 555-7218

Email: d.archer@calderwoodharkness.com

cc: Priya Anand, Esq., Calderwood & Harkness LLP Gwendolyn R. Kwan, Esq., Kwan, Delacroix & Samuels LLP Benjamin T. Okafor, Esq., Kwan, Delacroix & Samuels LLP Tessa L. Brannigan, Esq., Minor's Counsel

Encl.: None

CONFIDENTIAL
CALDERWOOD & HARKNESS LLP Attorneys at Law
777 South Flower Street, Suite 3400 Los Angeles, California 90017
Telephone: (213) 555-7200 Facsimile: (213) 555-7201 www.calderwoodharkness.com
October 20, 2023
Hon. Constance M. Yee (Ret.) c/o Pacific Coast Dispute Resolution Services 801 South Figueroa Street, Suite 1250 Los Angeles, California 90017
Re: Mediation Scheduling — In re Fonseca / Medrano Custody & Parenting Plan Case No.: 22STFL09847, Superior Court of California, County of Los Angeles C&H Matter No.: 1035-00002
Dear Judge Yee:
I write on behalf of Calderwood & Harkness LLP, counsel of record for Marguerite D. Fonseca (Petitioner) in the above-referenced custody and parenting-plan matter. The purpose of this letter is to respectfully request the scheduling of mediation sessions before Your Honor and to provide the background information we believe will be helpful in facilitating the process. As set forth in greater detail below, the parties have reached a point in the proceedings at which private mediation represents the most constructive path toward resolution of the outstanding custody, visitation, and child-support issues.
By way of brief procedural background, this matter arises from the dissolution of a registered domestic partnership between Ms. Fonseca and Rafael J. Medrano (Respondent). A judgment of dissolution was entered on November 3, 2022, in Case No. 22STFL09847, in the Superior Court of California, County of Los Angeles, Department 56. Pursuant to the terms of that judgment, the court expressly reserved jurisdiction over all issues pertaining to legal and physical custody, visitation and timeshare, and child support. Those reserved issues are now ripe for resolution, and both parties have expressed a strong desire to resolve them through mediation rather than contested litigation, in the interest of minimizing the emotional toll on their young children and preserving a cooperative co-parenting relationship going forward.
Nature of the Dispute
The parties, Marguerite D. Fonseca and Rafael J. Medrano, are the parents of two minor children:
1. Isabela Luz Fonseca-Medrano, born February 11, 2017 (currently age 6); and
2. Mateo Elías Fonseca-Medrano, born August 29, 2019 (currently age 4).
Ms. Fonseca and Mr. Medrano were registered domestic partners in the State of California from September 12, 2015, until the dissolution of the partnership was finalized by entry of judgment on November 3, 2022. Both children were born during the course of the partnership, and there is no dispute as to parentage. As noted above, the dissolution judgment specifically reserved jurisdiction over custody, visitation, and child support, as those issues were not resolved at the time the judgment was entered.
On May 2, 2023, Ms. Fonseca filed a Request for Order (RFO) seeking primary legal and physical custody of both minor children, together with guideline child support. The matter came before the Honorable Marcus T. Reyes, sitting in Department 56, for a hearing on May 30, 2023, at which time the court entered a temporary custody order establishing a 60/40 timeshare arrangement in favor of Ms. Fonseca for the pendency of the matter. That temporary order remains in effect as of the date of this letter.
On June 22, 2023, the court appointed Minor's Counsel, Tessa L. Brannigan, Esq., to represent the interests of both minor children in these proceedings, pursuant to California Family Code Section 3150. Ms. Brannigan has been actively involved in the matter since her appointment and has had the opportunity to meet with both children, both parents, and each party's counsel.
By stipulation filed with the court on July 14, 2023, the parties agreed to the appointment of a custody evaluator, Dr. Elena V. Sorensen, Psy.D., of Sorensen Family Behavioral Health, P.C., to conduct a comprehensive child custody evaluation under Evidence Code Section 730. Dr. Sorensen's evaluation included individual interviews with both parents, collateral interviews, home visits to each parent's residence, psychological testing, and direct observation of each parent's interaction with the children. Dr. Sorensen completed her evaluation and delivered her written report to all counsel and to the court on October 6, 2023. The report and its recommendations will, of course, form an important part of the mediation discussions.
With the custody evaluation now complete, both parties are prepared to engage in good-faith mediation to attempt to resolve all outstanding custody, parenting-plan, and child-support issues without the necessity of a contested hearing. Both counsel have conferred and are in agreement that mediation before Your Honor represents the best opportunity to achieve a comprehensive and durable resolution that serves the best interests of the children.
We note for the record that the court file in this matter has been sealed pursuant to California Rules of Court, Rule 2.550 et seq. The sealing order was entered in recognition of the public-facing nature of both parties' careers in the entertainment industry and, most importantly, the paramount privacy interests of the minor children. Accordingly, we respectfully request that all communications, briefs, and materials exchanged in connection with the mediation be treated with the highest degree of confidentiality, consistent with the court's sealing order and the protections afforded to mediation communications under Evidence Code Sections 1115 through 1128.
Issues for Mediation
We anticipate that the mediation will encompass the following issues, each of which remains unresolved between the parties:
1. Legal and Physical Custody. The parties seek to reach agreement on the allocation of legal custody (sole or joint) and physical custody (sole or joint, with a primary custodial parent designation, if appropriate) for both Isabela and Mateo.
2. Timeshare and Visitation Schedule. The parties need to establish a comprehensive timeshare and visitation schedule addressing the regular school-year schedule, summer vacation periods, and all major holidays and school breaks. The schedule should account for the children's ages, developmental needs, and current school enrollment.
3. Child Support. The parties intend to address the calculation of child support, including whether any deviation from the California guideline amount is warranted under the circumstances of this case, taking into account each parent's income, the agreed-upon timeshare, and the statutory factors set forth in Family Code Sections 4053 through 4057.
4. Education Costs. Both children are currently enrolled at Ridgeview Academy, a private school located in Sherman Oaks, California. The parties will need to address the allocation of tuition, fees, and related educational expenses between them, as well as a decision-making framework for future educational decisions.
5. Extracurricular Activity Costs. The parties seek to agree upon a methodology for the allocation of costs associated with the children's extracurricular activities, including enrollment fees, equipment, travel for competitions or performances, and related expenses.
6. Healthcare Cost-Sharing. The parties will address the allocation of uninsured and unreimbursed healthcare expenses for the children, including medical, dental, orthodontic, vision, and mental health costs, consistent with Family Code Section 4062.
7. Travel and On-Location Work Provisions. Both parents are employed in the entertainment industry. Mr. Medrano works as a freelance cinematographer, and his professional obligations require periodic travel to out-of-state filming locations for extended periods. The parenting plan will need to address travel notice requirements, make-up time provisions, and protocols for maintaining the children's contact with the traveling parent during periods of absence.
8. Parenting Plan Coordinator. The parties wish to discuss the appointment of a parenting plan coordinator to assist in the implementation and ongoing management of the parenting plan, including the resolution of day-to-day scheduling disputes and the interpretation of plan provisions.
9. Confidentiality and Non-Disparagement Provisions. Given the parties' public profiles and the court's sealing order, the parenting plan should include robust confidentiality provisions restricting each party's public disclosure of custody arrangements, as well as mutual non-disparagement provisions to protect the children's emotional well-being.
We recognize that additional issues may arise during the course of mediation, and we are prepared to address any matters that Your Honor believes would benefit from discussion in this forum.
Identification of Counsel and Participants
For Your Honor's reference and to facilitate coordination, we provide the following identification of all counsel and participants who will be involved in the mediation:
Petitioner's Counsel — Calderwood & Harkness LLP:
Priya Anand, Partner (Billing Partner) Devon Archer, Associate (Lead Associate; Primary Contact for Scheduling and Mediation Logistics)
Calderwood & Harkness LLP 777 South Flower Street, Suite 3400 Los Angeles, California 90017
Devon Archer Direct Telephone: (213) 555-7218 Devon Archer Email: d.archer@calderwoodharkness.com
Respondent's Counsel — Kwan, Delacroix & Samuels LLP:
Gwendolyn R. Kwan, Partner, Lead Counsel for Respondent (CA State Bar No. 218453) Benjamin T. Okafor, Associate (CA State Bar No. 312776)
Kwan, Delacroix & Samuels LLP 4400 Riverside Drive, Suite 700 Burbank, California 91505
Minor's Counsel:
Tessa L. Brannigan, Esq. (CA State Bar No. 267894) Law Offices of Tessa L. Brannigan 6320 Canoga Avenue, Suite 1500 Woodland Hills, California 91367
Ms. Brannigan was appointed by the court on June 22, 2023, pursuant to Family Code Section 3150, and represents the interests of both minor children. We respectfully request that Ms. Brannigan be included in all mediation-related communications, scheduling correspondence, and sessions, as her participation is essential to ensuring that the children's interests are fully represented throughout the process.
Both parties — Marguerite D. Fonseca and Rafael J. Medrano — will attend the mediation sessions in person.
Scheduling Request and Availability
We respectfully request that an initial mediation session be scheduled at the earliest mutually available date, with the goal of commencing mediation in mid-to-late November 2023. Counsel for both parties have conferred regarding availability, and we are pleased to report that both sides are generally available during the weeks of November 13, 2023, and November 20, 2023, for the first session. We respectfully request that Your Honor's office coordinate directly with all counsel of record and Minor's Counsel to confirm a specific date and time.
Based on the number and complexity of the issues outlined above, we anticipate that the matter may require two to three mediation sessions to reach a comprehensive resolution. We respectfully request that, following the initial session, subsequent sessions be scheduled approximately three to four weeks apart to allow sufficient time for the parties and their counsel to evaluate proposals, gather any additional information that may be requested, and prepare counterproposals between sessions.
Both parties have expressed a preference for full-day sessions, running from approximately 9:00 a.m. to 5:00 p.m., to allow adequate time for thorough discussion of all issues. We further request that the sessions be held at the offices of Pacific Coast Dispute Resolution Services, located at 801 South Figueroa Street, Suite 1250, Los Angeles, California 90017, unless Your Honor's office suggests an alternative venue.
Confidentiality
As noted above, the court file in this matter has been sealed pursuant to California Rules of Court, Rule 2.550 et seq. We wish to emphasize that all mediation communications, briefs, memoranda, correspondence, and other materials exchanged in connection with the mediation should be treated as strictly confidential, consistent with the court's sealing order and the statutory protections afforded to mediation communications under Evidence Code Sections 1115 through 1128.
The parties understand that they will be required to submit confidential mediation briefs in advance of each session, in accordance with Your Honor's standard protocol. We respectfully request confirmation of Your Honor's preferred timing for receipt of those briefs — for example, whether they should be submitted five business days or one full calendar week prior to each scheduled session — so that counsel may plan accordingly.
Mediation Fee Arrangements
We respectfully request confirmation of Your Honor's current mediation fee schedule, as administered through Pacific Coast Dispute Resolution Services, including the hourly or daily rate, any required retainer or deposit, and the cancellation policy.
The parties have agreed to split all mediation fees equally, on a 50/50 basis. We request that invoices be directed separately to counsel for each party, as follows:
• Petitioner's share: Calderwood & Harkness LLP, 777 South Flower Street, Suite 3400, Los Angeles, California 90017, Attention: Devon Archer, C&H Matter No. 1035-00002.
• Respondent's share: Kwan, Delacroix & Samuels LLP, 4400 Riverside Drive, Suite 700, Burbank, California 91505, Attention: Gwendolyn R. Kwan.
Closing
We wish to express our sincere appreciation for Your Honor's willingness to serve as mediator in this matter. Your Honor's extensive experience on the bench and widely recognized expertise in high-asset family law matters give both parties considerable confidence that the mediation process will be conducted with the care, sensitivity, and thoroughness that the circumstances of this case require. Both Ms. Fonseca and Mr. Medrano share a genuine commitment to reaching a resolution that serves the best interests of Isabela and Mateo, and they believe that Your Honor's involvement will greatly facilitate that goal.
Should Your Honor require any additional information, documentation, or preliminary submissions in advance of the first mediation session, we are prepared to provide such materials promptly upon request. We would be grateful if scheduling could be coordinated at Your Honor's earliest convenience so that the parties may proceed without unnecessary delay.
All scheduling communications may be directed to the undersigned at the contact information provided below. I am available at your convenience and will endeavor to respond to any inquiries within one business day.
Thank you for your time and attention to this matter. We look forward to working with Your Honor toward a resolution that protects the well-being of both children.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Devon Archer Associate 777 South Flower Street, Suite 3400 Los Angeles, California 90017 Telephone: (213) 555-7218
Email: d.archer@calderwoodharkness.com
cc: Priya Anand, Esq., Calderwood & Harkness LLP Gwendolyn R. Kwan, Esq., Kwan, Delacroix & Samuels LLP Benjamin T. Okafor, Esq., Kwan, Delacroix & Samuels LLP Tessa L. Brannigan, Esq., Minor's Counsel
Encl.: None

CONFIDENTIAL

CALDERWOOD & HARKNESS LLP

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