Extract to table

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We also anticipate that Holt may assert his Fifth Amendment privilege against self-incrimination, which would prevent TMC from compelling his testimony in the internal investigation and would limit his cooperation to any extent he voluntarily agrees to provide

Chu's exposure is therefore lower than Holt's, but she must be carefully managed as a fact witness whose testimony could be significant in establishing the mechanics of the alleged price-fixing

The internal investigation must be accelerated and expanded; key witnesses must be prepared for proffer sessions; document production must be completed on an aggressive timeline; and compliance remediation measures must be designed and implemented

Any engagement with Holt must be voluntary on his part

Once Holt is represented, all communications between TMC (or Calderwood & Harkness) and Holt must be conducted through his attorney