We have retained Dawn Alba to assist in connection with matters relating to AMC Project Popcorn.

Dawn Alba’s scope of engagement includes the review and analysis of relevant documents, including but not limited to: the Statement of Facts, settlement hearing transcripts, and the Daniel Myer Affidavit. The purpose of this review is to support us in preparing and drafting a records request pursuant to Sections 219 and 220 of the Delaware General Corporation Law (“DGCL”).

As part of this engagement, Dawn Alba shall advise on and assist in the preparation of such records request, including identifying appropriate categories of books, records, and stockholder information subject to inspection.

If deemed necessary, Dawn Alba shall draft a formal demand for inspection of books and records and/or stockholder information.