Client Update Drafts

Matter: M-2041 Meridian Holdings

Stage: Discovery · CMC directions in force

Discovery review has surfaced two internal emails from March 2022 that materially undermine our narrative on the Kessler transaction. Partner review recommends we refuse voluntary production and force a specific disclosure application from opposing counsel.

Counsel is preparing a redaction protocol. If forced production is ordered, exposure could reach $2.4M plus reputational fallout.

Internal note: Client GC not yet informed of the two problematic emails. Partner will discuss at next in-person meeting.

Fees: Retainer at 74% burn. Additional $32K anticipated for expert forensic work.

Meridian Holdings — Fortnight Update #6

Prepared by: M. Chen · Reviewer: A. Okafor

Following the case management conference, we have made significant progress on discovery. The directions issued by the Court permit a narrowed scope of documents, which the team is now processing.

The counterparty has begun to exchange initial documents, and we are conducting a careful review to ensure both accuracy and privilege protection. We expect to have completed our review within the next fortnight.

We anticipate an in-person session with your general counsel in the coming week to discuss strategic considerations arising from the discovery exercise.

The matter remains within the agreed budget envelope. Please let us know if any additional context would be helpful.

— Ashworth & Vance LLP