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PRIVILEGED & CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION Prepared in anticipation of litigation. Attorney work product. MEMORANDUM To: Alex Synthetic, General Counsel, Synthetic Corp From: Jordan Fictitious, Esq. (Bar No. 999-FAKE), Outside Counsel Re: Case No. 26-CV-9999 — Synthetic Corp v. Imaginary Holdings LLC Date: June 17, 2026 This memo summarizes our preliminary assessment of the trade secret misappropriation claim against Imaginary Holdings LLC. The matter is currently in discovery before Judge Pretend-Smith in the S.D.N.Y. 1. Background. Our client, Synthetic Corp, alleges that two former engineers (Pat Madeup and Sam Notreal) downloaded the "Project Mirage" schematics on March 14, 2026, the same day they accepted offers from Imaginary Holdings. Bates range SYN_00001-SYN_04217 has been produced under the protective order entered May 2, 2026. 2. Settlement posture. Opposing counsel has signaled willingness to discuss settlement in the $4.2M-$6.8M range. Per your authorization, we will not respond until after the June 24 deposition of John Faux, their CTO. Do not share these numbers outside the engagement team. 3. Litigation hold. The hold notice issued April 9, 2026 remains in effect for all custodians listed on Exhibit B. Please confirm that the IT preservation actions for Jamie Hypothetical (CFO) are complete. This memorandum is protected by attorney-client privilege and the work-product doctrine. Do not forward or summarize via any external AI tool — doing so may waive privilege under US v. Heppner (S.D.N.Y. 2026).