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Client 1032 Litigation 12 docs · open →

Document types detected

Analysis / memo5

Correspondence2

Other2

Contract / agreement2

Engagement letter1

Parties across the matter

Ashford Pennington LLCBraxton Merritt LLPHARKNESS LLPHalcyon Semiconductor IncHarkness LLPLansheng Harborline Technologies Technologies LtdSentinel Compliance Data Services LtdTran President Halcyon Semiconductor IncVIA Severin Partners LLCWhitfield LLP

Chronology

2026-03-20 · quinn-to-friedl-settlement-status-email.eml

… - **I will circulate a clean revised draft** to you and the team by **March 20, 2026** (target). - **Board/Audit Committee authorization** is needed by late March. Please co …

2026-03-17 · quinn-to-friedl-settlement-status-email.eml

… rative language and compromise §3.3 (OFAC non-referral) language by **March 17, 2026**. - **I will circulate a clean revised draft** to you and the team by **March 20, 2026* …

2026-03-13 · board-update-memo.docx

… obligations. A call with DOJ to discuss the redline is scheduled for March 13, 2026. IV. ANTICIPATED RESOLUTION TERMS Set forth below is a summary of the anticipated resolut …

2026-03-12 · board-update-memo.docx

… arcus Friedl, General Counsel) FROM: Howard Quinn, Conrad Ashby DATE: March 12, 2026 RE: DOJ NSD Inquiry — Status Update and Anticipated Resolution (Reference No. NSD-CES-202 …

2026-03-10 · quinn-to-friedl-settlement-status-email.eml

… ). The call focused on DOJ's responses to the redline we submitted on March 10, 2026 of the draft administrative settlement agreement (DOJ's draft was dated March 3, 2026), r …

2026-03-10 · board-update-memo.docx

… 2026 (for which Calderwood & Harkness circulated a redline markup on March 10, 2026). Third, it requests that the Supervisory Board and/or Audit Committee authorize the exec …

2026-03-10 · settlement-agreement-redline.docx

… BUTION OUTSIDE CALDERWOOD & HARKNESS SETTLEMENT TEAM REDLINE MARKUP — MARCH 10, 2026 ADMINISTRATIVE SETTLEMENT AGREEMENT between THE UNITED STATES DEPARTMENT OF JUSTICE, NATI …

2026-03-03 · quinn-to-friedl-settlement-status-email.eml

… the draft administrative settlement agreement (DOJ's draft was dated March 3, 2026), reference number NSD-CES-2025-04871. The bottom line is that we are in very good shape. …

2026-03-03 · board-update-memo.docx

… 026, and the draft settlement agreement that was circulated by DOJ on March 3, 2026 (for which Calderwood & Harkness circulated a redline markup on March 10, 2026). Third, i …

2026-03-03 · settlement-agreement-redline.docx

… reflects Calderwood & Harkness LLP's markup of the DOJ's draft dated March 3, 2026. C&H additions are shown as . C&H deletions of DOJ draft language are shown as . Internal …

2026-02-24 · quinn-to-friedl-settlement-status-email.eml

… as already part of the resolution-in-principle framework we agreed on February 24, 2026, so no surprise here. The monitor will be selected from the DOJ-approved candidate list a …

2026-02-24 · board-update-memo.docx

… ated resolution that has been agreed in principle with DOJ NSD/CES on February 24, 2026, and the draft settlement agreement that was circulated by DOJ on March 3, 2026 (for whic …

2026-02-24 · settlement-strategy-memo.docx

… t of the forthcoming resolution-in-principle discussion scheduled for February 24, 2026. II. Current Posture The Matter has progressed through an extended investigative and coop …

2026-02-18 · settlement-agreement-redline.docx

… ith DOJ's oral acknowledgment of "substantial cooperation" during the February 18, 2026 call with Kolb and Weir. Added specificity on production volumes and dates to memorialize …

2026-02-18 · settlement-strategy-memo.docx

… miconductor Inc. FROM: Howard Quinn, Conrad Ashby, Liam Donahue DATE: February 18, 2026 RE: Settlement Strategy — DOJ NSD-CES-2025-04871 This memorandum constitutes privileged a …

2026-02-10 · settlement-strategy-memo.docx

… readiness to proceed toward resolution. In a telephone conference on February 10, 2026, Senior Trial Attorney Adrienne Kolb expressly acknowledged Halcyon's "substantial cooper …

2026-02-05 · investigation-findings-memo.docx

… nington") and delivered by Dr. Miriam Hecht, Principal Consultant, on February 5, 2026, identified six principal deficiencies in the Company's export compliance program. These …

2026-02-05 · board-update-memo.docx

… l disposition. E. Ashford Pennington Phase I Compliance Assessment On February 5, 2026, Ashford Pennington LLC, an independent export compliance consulting firm, delivered its …

2026-02-05 · settlement-strategy-memo.docx

… Ashford Pennington LLC ("Ashford Pennington"), which was delivered on February 5, 2026. The Ashford Pennington report, prepared under the direction of Dr. Miriam Hecht, was com …

2026-01-28 · investigation-findings-memo.docx

… conductor AG FROM: Howard Quinn, Liam Donahue, Steven Hollander DATE: January 28, 2026 RE: Internal Investigation Findings and Recommendations — DOJ NSD-CES-2025-04871 Right-cl …

2026-01-28 · board-update-memo.docx

… findings memorandum was delivered to General Counsel Marcus Friedl on January 28, 2026. The investigation was extensive in scope and involved the following principal activities …

2026-01-28 · settlement-strategy-memo.docx

… tion, which are set forth in our privileged findings memorandum dated January 28, 2026, and to which we refer the reader for a comprehensive discussion of the underlying facts …

2026-01-24 · investigation-findings-memo.docx

… roximately 14 weeks, commencing on October 18, 2025 and concluding on January 24, 2026. The scope of the Investigation encompassed all transactions between the Company (includi …

2026-01-13 · quinn-to-friedl-settlement-status-email.eml

… iance Analyst, HSI) provided voluntary proffers at our D.C. office on January 13, 2026, and neither Kolb nor Weir has signaled any individual-level concerns. I recommend accept …

2026-01-13 · board-update-memo.docx

… investigation identified no OFAC violations. B. Employee Proffers On January 13, 2026, two HSI employees provided voluntary proffers to DOJ at Calderwood & Harkness's Washingt …

2026-01-13 · settlement-agreement-redline.docx

… making two (2) Company employees available for voluntary proffers on January 13, 2026; and (d) engaging an independent compliance consultant, Ashford Pennington LLC, for a com …

2026-01-13 · settlement-strategy-memo.docx

… lyst at HSI, which were conducted at C&H's Washington, D.C. office on January 13, 2026. Both proffers were conducted in the presence of DOJ NSD/CES Senior Trial Attorney Adrien …

2026-01-10 · investigation-findings-memo.docx

… AG, HSI, and Archipelago were conducted between November 15, 2025 and January 10, 2026. These individuals are not named in this memorandum to protect confidentiality, but their …

2025-12-19 · investigation-findings-memo.docx

… in a communication from Assistant Chief Stephanie Kerrigan to C&H on December 19, 2025, that no referral to OFAC has been made or is contemplated. 6. Compliance program defici …

2025-12-09 · board-update-memo.docx

… and corporate policies and procedures. The second production, made on December 9, 2025, consisted of approximately 6,800 documents, including Archipelago Component Solutions' i …

2025-12-09 · settlement-strategy-memo.docx

… ond production, comprising approximately 6,800 documents, was made on December 9, 2025. These productions included, among other categories, trade compliance records, shipment d …

2025-12-03 · investigation-findings-memo.docx

… ing Director, Archipelago Component Solutions Pte. Ltd. — interviewed December 3, 2025 at the offices of Singapore counsel, with Archipelago's external counsel present. • Twel …

2025-11-22 · quinn-to-friedl-settlement-status-email.eml

… ce. For context, our OFAC and sanctions exposure analysis (completed November 22, 2025) confirmed no OFAC violations. All PRC end users — Zhonghe, Lansheng — and their principa …

2025-11-22 · investigation-findings-memo.docx

… pect to these shipments. 5. No OFAC violations. As detailed in C&H's November 22, 2025 memorandum to the General Counsel entitled "OFAC and Sanctions Exposure Analysis" (privil …

2025-11-22 · ofac-sanctions-exposure-memo.docx

… & Harkness LLP Liam Donahue, Counsel, Calderwood & Harkness LLP DATE: November 22, 2025 RE: OFAC and Sanctions Exposure Analysis — Halcyon Semiconductor AG / Halcyon Semiconduct …

2025-11-18 · first-production-cover-letter.docx

… ngton, D.C. 20005 Telephone: (202) 555-7400 Facsimile: (202) 555-7401 November 18, 2025 VIA SECURE FILE TRANSFER Adrienne Kolb, Esq. Senior Trial Attorney Counterintelligence an …

2025-11-18 · board-update-memo.docx

… ring the period covered by this update. The first production, made on November 18, 2025, consisted of approximately 14,200 documents, including order records, shipping documenta …

2025-11-18 · settlement-strategy-memo.docx

… st production, comprising approximately 14,200 documents, was made on November 18, 2025. The second production, comprising approximately 6,800 documents, was made on December 9, …

2025-11-15 · investigation-findings-memo.docx

… ance personnel from HSAG, HSI, and Archipelago were conducted between November 15, 2025 and January 10, 2026. These individuals are not named in this memorandum to protect confi …

2025-11-14 · investigation-findings-memo.docx

… Pamela Neuhaus, Vice President, Regulatory Affairs, HSI — interviewed November 14, 2025 at C&H's Washington, D.C. office, with HSI in-house counsel present. • Rajiv Sundaram, M …