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(Jones, Laura Davis) (Entered: 09/08/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/476881299/","id":476881299,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71950617/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/492456577/","id":492456577,"tags":[],"absolute_url":"/docket/71950617/1036/american-signature-inc/","date_created":"2026-09-03T13:40:49.993763-07:00","date_modified":"2026-09-03T14:01:54.555937-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"1036","attachment_number":null,"pacer_doc_id":"042023175093","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Certificate of No Objection - No Order Required","acms_document_guid":""}],"date_created":"2026-09-03T13:40:49.960012-07:00","date_modified":"2026-09-04T08:04:26.763601-07:00","date_filed":"2026-09-03","time_filed":"16:39:42","entry_number":1036,"recap_sequence_number":"2026-09-03.002","pacer_sequence_number":3708,"description":"Certificate of No Objection - No Order Required Regarding Fifth Monthly Application for Compensation and Reimbursement of Expenses of Pachulski Stang Ziehl & Jones LLP, as Counsel for the Debtors and Debtors in Possession, for the Period from April 1, 2026 Through April 30, 2026 (related document(s)1000) Filed by American Signature, Inc.. (Jones, Laura Davis) (Entered: 09/03/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/476843067/","id":476843067,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/71950617/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/492417718/","id":492417718,"tags":[],"absolute_url":"/docket/71950617/1035/american-signature-inc/","date_created":"2026-09-03T11:01:39.131086-07:00","date_modified":"2026-09-09T13:28:27.769142-07:00","sha1":"7b6b5da1131f1586ce36e7c13698bd25e59a14d7","page_count":32,"file_size":11779627,"filepath_local":"recap/gov.uscourts.deb.199876/gov.uscourts.deb.199876.1035.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.deb.199876/gov.uscourts.deb.199876.1035.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 25-12105-JKS Doc 1035 Filed 09/03/26 Page 1 of 32\n\nIN THE UNITED STATES BANKRUPTCY COURT\nFOR THE DISTRICT OF DELAWARE\n\nIn re: ~ a Pad\nAMERICAN SIGNATURE, INC.., et al.,\nDebtors.\n\nChapter 11\nCase No. 25-12105 (JKS)\n(Jointly Administered)\n\nDocket Ref. Nos. 970, 1009\nHearing Date: September 10, 2026 at 9:30 a.m.\n\nMOVANT JAMYLA NOBLE\u2019S REPLY IN\nSUPPORT OF MOTION FOR RELIEF FROM\nTHE AUTOMATIC STAY AND IN\nRESPONSE TO DEBTORS\u2019 OBJECTION\n\nJamyla Noble (\u201cMovant\u201d), appearing pro se, respectfully submits this Reply in support of her\nMotion for Relief from the Automatic Stay pursuant to 11 U.S.C. \u00a7 362(d)(1) [Docket No. 970]\n(the \u201cMotion\u201d) and in response to the Debtors\u2019 Objection [Docket No. 1009] (the \u201cObjection\u2019),\nand respectfully states as follows:\n\nINTRODUCTION\n\n1. Movant seeks limited relief from the automatic stay for the purpose of allowing her\npending employment discrimination action, Noble v. American Signature, Inc., Case No.\n1:26-cv-00841-JPH-KMB, pending in the United States District Court for the Southern\nDistrict of Indiana (the \u201cIndiana Action\u201d), to proceed to determination of liability and\ndamages.\n\n2. Movant does not seek through the present Motion authorization to enforce, execute\nupon, or collect any judgment against property of the bankruptcy estate. Movant seeks\nlimited relief permitting the Indiana Action to proceed to determination, while reserving\nthe treatment and satisfaction of any resulting judgment for further proceedings and\norders of this Court.\n\n3. The Debtors contend that relief should nevertheless be denied because continuation of\nthe Indiana Action would impose defense costs upon the estates, because Movant\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 2 of 32\n\nallegedly suffers no meaningful hardship from maintenance of the stay, and because\nMovant allegedly has provided no evidence demonstrating a probability of success on\nthe merits.\n\nThe documentary record presented with this Reply materially addresses those\narguments. In particular, ASI\u2019s own prepetition representations concerning its Human\nResources investigation substantiate central factual allegations underlying the Indiana\nAction.\n\n1. THE RECORD DEMONSTRATES THAT MOVANT\u2019S\nUNDERLYING CLAIM IS NOT MERELY SPECULATIVE\n\n10.\n\n11.\n\nThe Objection asserts that Movant \u201chas provided no evidence\u201d demonstrating that she is\nlikely to prevail on the underlying merits of the Indiana Action. The evidence presently\navailable demonstrates, at minimum, that Movant has a bona fide, evidence-supported\nclaim warranting adjudication in the court in which that action is already pending.\n\nIn an October 7, 2024 Position Statement submitted on behalf of American Signature,\nInc. (\u201cASI\u201d) to the Equal Employment Opportunity Commission (\u201cEEOC\u201d), ASI addressed\nits investigation of Movant's concerns regarding an intimate video and workplace\ndiscussion of that video. Relevant portions of ASI's Position Statement are attached as\nExhibit A.\n\nASI represented to the EEOC that its Human Resources Partner investigated Movant's\nconcerns and determined that a former employee had shown the intimate video to\nemployee Will Bridgeforth and that Bridgeforth subsequently described the video in\ndetail to employee Wendi Roddy.\n\nThus, although the parties dispute the ultimate legal consequences of the conduct and\nthe adequacy of ASI\u2019s response, ASI's own investigation substantiated significant\nportions of the factual events underlying the Indiana Action. Movant's claim therefore\ndoes not rest solely upon her unsupported allegations.\n\nASI further represented that Bridgeforth received a written warning and that Roddy\nreceived a \u201cfirst and final\u201d warning. The corrective-action documentation concerning\nRoddy is attached as Exhibit B.\n\nMovant acknowledges that ASI represents that Bridgeforth received a written warning.\nMovant does not contend that no discipline occurred. However, unlike the\ncorrective-action documentation concerning Roddy, Movant has not been provided the\ncorresponding written warning or other disciplinary record concerning Bridgeforth. The\npresently available materials therefore contain ASI's representation that Bridgeforth was\ndisciplined, but do not independently document the nature, terms, timing, or substance\nof that discipline.\n\nThis distinction is relevant because ASI\u2019s Team Member Handbook contains policies\nprohibiting discrimination and harassment and sets forth ASI\u2019s procedures for\nresponding to harassment complaints. The Handbook further identifies violation of ASI\u2019s\nnon-discrimination or non-harassment policies among the violations that \u201cWill Result in\n\f12\n\n13.\n\n14.\n\nCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 3 of 32\n\nImmediate Termination.\u201d Relevant portions of the applicable Handbook are attached as\nExhibit C.\n\nThe conduct substantiated by ASI's own investigation\u2014including the dissemination and\ndetailed workplace discussion of an intimate sexual video involving Movant\u2014implicates\nthe very type of sexual and harassing conduct addressed by ASI's non-harassment\npolicies. Yet, notwithstanding the Handbook'\u2019s identification of violations of ASI's\nnon-discrimination or non-harassment policies among violations that \u201cWill Result in\nImmediate Termination,\u201d ASI\u2019s own account reflects that neither Bridgeforth nor Roddy\nwas terminated for the conduct at issue. ASI represents that Bridgeforth received a\nwritten warning and that Roddy received a First and Final Warning. Movant therefore\ndisputes not only whether ASI's remedial response was adequate and reasonably\neffective, but also whether ASI appropriately applied and enforced its own\nnon-harassment policies after its investigation substantiated material portions of the\nunderlying conduct. These issues warrant development through discovery and\nadjudication in the Indiana Action.\n\nThose issues are appropriately developed through discovery and adjudicated in the\nIndiana Action. Movant does not ask this Court to adjudicate the merits of her Title VII\nclaim through this stay-relief proceeding.\n\nRather, Exhibits A through C are offered to directly address the Debtors\u2019 assertion that\nMovant has presented no evidence supporting a probability of success. ASI\u2019s own\ninvestigation and records provide documentary support for significant factual allegations\nunderlying Movant's claim.\n\nll. CONTEMPORANEOUS EVIDENCE FURTHER\nSUPPORTS MOVANT\u2019S ACCOUNT AND THE EFFECT OF\nTHE WORKPLACE EVENTS\n\n15.\n\n16.\n\n7.\n\nMovant has also obtained a signed statement from Phyllis J. Bonds, MS, NCC, LMHC,\nBoard Certified Professional Counselor, who treated Movant intermittently from January\n18, 2022 through April 22, 2024. The statement is attached as Exhibit D.\n\nMs. Bonds states that during Movant's final counseling session, Movant reported that the\npreceding six months had been very difficult and that an incident at work had\nsignificantly affected her mentally, physically, emotionally, and financially. Ms. Bonds\nfurther documents Movant's reports concerning the intimate video, humiliation, difficulty\nbeing at work, and significant emotional and functional consequences during the\nrelevant period.\n\nImportantly, Ms. Bonds expressly states that the statements in her letter were condensed\nand arrived at through a review of actual session notes. Exhibit D therefore reflects\ninformation derived from contemporaneous counseling records predating the present\nlitigation and the current bankruptcy stay dispute.\n\f18.\n\n19.\n\n20.\n\nCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 4 of 32\n\nMovant also possesses a contemporaneous October 17, 2023 Messenger conversation\nwith another ASI employee, attached as Exhibit E. The conversation occurred within\ndays of the workplace confrontation concerning the intimate video.\n\nIn that conversation, Movant stated that she had never consented to the video being\nshown to others, identified Bridgeforth in connection with the video, described herself as\nexhausted by the situation, discussed the workplace investigation, and stated that\nmanagement had informed her that employees would be interviewed.\n\nExhibit E is not offered to establish that the other participant personally viewed Movant's\nvideo, and Movant does not make that assertion based upon the conversation. Rather,\nExhibit E corroborates that Movant was contemporaneously discussing the\ndissemination of the video, her lack of consent, her resulting distress, and ASI\u2019s\nworkplace investigation in October 2023\u2014well before commencement of the Indiana\nAction or the present stay dispute.\n\nlll. CONTINUED MAINTENANCE OF THE STAY IMPOSES\nSUBSTANTIAL HARDSHIP ON MOVANT\n\n21.\n\n22.\n\n23.\n\n24.\n\n25.\n\n26.\n\nThe Debtors contend that Movant \u201cwill not suffer any harm\u2019 if relief is denied because\nher claim can ultimately be addressed through the bankruptcy claims-allowance process.\nThe Objection further asserts that Movant has not articulated substantial prejudice\nresulting from delay.\n\nThat characterization does not adequately account for the nature of Movant's claim, the\nprocedural posture of the Indiana Action, or the evidentiary consequences of additional\ndelay.\n\nMovant pursued administrative relief through the EEOC before commencing the Indiana\nAction and subsequently timely filed the Indiana Action after receiving her Notice of Right\nto Sue. The Indiana Action is already pending in the United States District Court for the\nSouthern District of Indiana and is stayed because of the Debtors\u2019 bankruptcy\nproceedings.\n\nMovant's claim concerns alleged sex discrimination and a hostile work environment\narising from intensely personal workplace conduct. The evidence described above\nreflects that Movant was reporting substantial emotional and functional effects from\nthose events while she remained employed by ASI.\n\nContinued delay also carries concrete evidentiary consequences. The underlying events\nbegan in 2023. As additional time passes, memories may fade, witnesses may become\nmore difficult to locate, and relevant evidence may become increasingly difficult to\nobtain.\n\nOne employee directly involved in the events underlying the dispute, Wendi Roddy, is\nnow deceased. Additional delay therefore presents a meaningful risk to Movant's ability\nto fully develop and present evidence concerning events that already occurred several\nyears ago.\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 5 of 32\n\n27. Permitting the Indiana Action to proceed would allow liability and damages to be\ndetermined in the federal forum where Movant timely commenced her employment\naction following exhaustion of the EEOC process.\n\nIV. THE LIMITED RELIEF REQUESTED MITIGATES\nPREJUDICE TO THE ESTATE\n\n28. Movant recognizes the Debtors\u2019 concern that continuation of the Indiana Action may\nrequire expenditure of estate resources and acknowledges the Debtors\u2019 representation\nthat no applicable insurance is available to cover the claims asserted in the Indiana\nAction. The Debtors contend that they would therefore bear the costs of defending that\naction.\n\n29. The Motion does not presently seek authorization to collect from property of the\nbankruptcy estate. Movant seeks to proceed with the Indiana Action to determine liability\nand damages, while reserving the treatment and satisfaction of any resulting judgment\nfor further proceedings and orders of this Court.\n\n30. Accordingly, granting the Motion would not itself authorize collection of any resulting\njudgment from property of the bankruptcy estate. The treatment and satisfaction of any\njudgment obtained in the Indiana Action would remain subject to applicable bankruptcy\nlaw and further proceedings and orders of this Court.\n\n31. The relief presently sought is permission to proceed with the Indiana Action to determine\nliability and damages. Movant is not through the present Motion requesting authorization\nconcerning the ultimate treatment or satisfaction of any resulting judgment.\n\n32. Movant does not suggest that the Debtors\u2019 litigation-cost concerns are irrelevant. Those\nconcerns, however, should be weighed against the limited nature of the relief presently\nrequested, the evidentiary support for Movant's underlying claim, and the substantial\nhardship imposed by continued suspension of an already-pending federal employment\naction.\n\n33. The Debtors also contend that granting relief could encourage other creditors to seek\nsimilar relief. Movant respectfully submits that this Motion should be determined upon its\nown particular facts and circumstances, including the existence of an already-pending\nfederal employment action, the nature of the underlying allegations, ASI\u2019s own\ninvestigation substantiating material factual allegations, the contemporaneous evidence\nsupporting Movant's account, and the risk associated with further deterioration of witness\navailability and evidence.\n\nV. THE BALANCE OF THE RELEVANT FACTORS\nSUPPORTS LIMITED RELIEF FROM THE STAY\n\n34. The Debtors identify three considerations relevant to determining whether cause exists\nunder 11 U.S.C. \u00a7 362(d)(1): (1) prejudice to the bankruptcy estate or debtor from\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 6 of 32\n\ncontinuation of the civil action; (2) comparative hardship to the non-debtor party from\nmaintenance of the stay; and (3) the creditor\u2019s probability of success on the merits.\n\n35. With respect to prejudice to the estates, Movant acknowledges that the Debtors may\nincur litigation expenses. However, the requested relief is limited to allowing the Indiana\nAction to proceed to determination of liability and damages, while reserving treatment\nand satisfaction of any resulting judgment for further proceedings and orders of this\nCourt.\n\n36. With respect to comparative hardship, continued delay substantially prejudices Movant's\nability to prosecute a fact-dependent employment action involving events dating to 2023.\nOne relevant employee is already deceased, and continued passage of time threatens\nthe availability and reliability of additional witness evidence.\n\n37. With respect to probability of success, the documentary evidence now presented directly\naddresses the Debtors\u2019 contention that Movant has provided no evidence supporting the\nmerits of her claim. ASI's own investigation determined that the intimate video was\nshown to an ASI employee and subsequently described in detail to another ASI\nemployee. ASI thereafter represents that corrective action was imposed. Exhibits D and\nE additionally provide contemporaneous support concerning Movant's account of the\nevents, the workplace investigation, and the emotional impact she reported during the\nrelevant period.\n\n38. Movant does not ask this Court to determine through the present Motion that she will\nultimately prevail in the Indiana Action. The ultimate merits remain for adjudication in that\naction. The present evidence demonstrates, however, that the Indiana Action is\nsupported by concrete evidence and presents genuine factual and legal issues\nappropriate for adjudication rather than a merely speculative claim.\n\n39. Under these circumstances, the balance of the relevant considerations supports granting\nlimited relief from the automatic stay so that the Indiana Action may proceed while this\nCourt retains authority over the treatment and satisfaction of any resulting judgment.\n\nCONCLUSION\n\nWHEREFORE, Movant Jamyla Noble respectfully requests that the Court overrule the Debtors\u2019\nObjection and grant her Motion for Relief from the Automatic Stay pursuant to 11 U.S.C. \u00a7\n362(d)(1), permitting Noble v. American Signaiure, Inc., Case No. 1:26-cv-00841-JPH-KMB, to\nproceed in the United States District Court for the Southern District of Indiana for determination\nof liability and damages, while reserving the treatment and satisfaction of any resulting judgment\nfor further proceedings and orders of this Court, and granting such other and further relief as the\nCourt deems just and proper.\n\nro Ze Movant\n\n5709 Ivy Knoll Ct Apt C\nIndianapolis, IN 4625\njamylanoble@gmail.com\nDated: August 27th 2026\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 7 of 32\n\nUNITED STATES BANKRUPTCY COURT - DISTRICT OF DELAWARE\nIn re: American Signature, Inc., et al.\nChapter 11 - Case No. 25-12105 (JKS) - Jointly Administered\n\nEXHIBIT A\n\nAmerican Signature, Inc.\nEEOC Position Statement\nOctober 7, 2024\n\nRelevant Pages 1-4\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 8 of 32\n\n52 East Gay Street\n\nP.O. Box 1008\nVU Cc) ie Y Columbus, Ohio 43216-1008\n\n614.464.6400 | vorys.com\n\nFounded 1909\n\nJacklyn J, Ford\n\nDirect Dial (614) 464-8230\nDirect Fax (614) 464-8230\nEmail jjford@vorys.com\n\nOctober 7, 2024\n\nFrederick Brubaker\n\nEEOC Investigator\n\nU.S. Equal Employment Opportunity Commission\nIndianapolis District Office\n\n115 W. Washington Street, South Tower, Suite 600\nIndianapolis, IN 43204\n\nRe: \u2014 Jamyla Noble v American Signature Inc.\nEEOC Charge No. 470-2024-05020\n\nDear Investigator Brubaker:\n\nOur firm represents Respondent American Signature, Inc. (hereinafter \u201cASI\u201d or the\n\u201cCompany\u201d) in the above-referenced charge of discrimination (the \u201cCharge\u201d) filed by Jamyla\nNoble (\u201cComplainant\u201d). Accordingly, please direct future communications related to this matter\nto my attention. Please also accept this correspondence and the attached exhibits as ASI\u2019s position\nstatement in response to the Charge.!\n\nContrary to the allegations in her Charge, Complainant has not been the subject of any type\nof harassment or discrimination, and her complaints regarding her coworkers have been fully and\nappropriately addressed. Accordingly, ASI requests that this Charge be dismissed with a finding\nof no probable cause.\n\nL. The Company\n\nASI operates retail furniture stores under the names American Signature Furniture and\nValue City Furniture. ASI typically refers to its employees as \u201cAssociates\u201d or \u201cTeam Members.\u201d\nWithin each store, hourly associates (office, warehouse, sales, and, in some stores, delivery\ndrivers) report to a management team, which typically includes a Store Manager (sometimes\nreferred to as the General Manager), one or more Assistant Managers (such as a Sales Manager),\nand, in some stores, a Warehouse Manager. Members of the sales team are referred to as Home\nFurnishings Consultants (\u201cHFCs\u201d) and are paid on an hourly draw-plus-commission basis.\n\n' This position statement, and the supporting documents, are based upon ASI\u2019s investigation and understanding of the\nfacts to date and are submitted solely in the interest of cooperating with your office in an effort to. achieve\nadministrative resolution of the Charge. This position statement is not an affidavit and is not intended to be used in\nany future proceeding. ASI in no way waives the right to modify, change, or amend this position statement as further\ninvestigation or facts may warrant. ,\n\nOhio | Washington, D.c. | Texas | Pennsylvania | California | London | Berlin\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 9 of 32\n\nVORYS\n\nFrederick Brubaker\nEEOC Investigator\nOctober 7, 2024\nPage 2\n\nPursuant to that compensation arrangement, HFC\u2019s are required to satisfy certain minimum sales\nexpectations each month. Failure to do so for four months out of any rolling 12 months results in\nautomatic termination. (See Sales Expectations Policy, attached as Exhibit 1.)\n\nASI is an equal opportunity employer committed to inclusion and non-discrimination for\nits associates and applicants. (See EEO Policy, attached as Exhibit 2.) The Company prohibits all\nforms of unlawful discrimination and harassment. The Company also provides its Team Members\nwith a toll-free hotline for reporting any form of discrimination or other workplace concern.\nComplainant acknowledged receipt and review of these policies. (See Handbook\nAcknowledgment, attached as Exhibit 3.)\n\nASI does not tolerate any form of discrimination or harassment, maintains well-publicized\npolicies prohibiting such conduct, and takes appropriate disciplinary measures, up to and including\ntermination, against any offender who violates these policies.\n\nIl. Complainant\u2019s Employment at ASI\n\nIn April, 2022, Complainant was hired by ASI as a Visual Merchandiser at ASI\u2019s Castleton\nstore in Indianapolis, Indiana. At her request, she subsequently became a. Home Furnishings\nConsultant (\u201cHFC\u201d), and remains in that role today. Complainant\u2019s employment at ASI has been\nlargely uneventful. However, she has consistently struggled to meet the requirements of the\nMinimum Sales Expectations Policy required for all HFCs. In April, May, and July of this year\nshe received Corrective Actions for failing to meet the minimum requirements. (See\nComplainant\u2019s Corrective Action Reports attached as Exhibit 4.) As a result, she is currently on a\nFinal Warning, and will be automatically terminated if she fails to meet the policy\u2019s minimum\nrequirements in any other month between now and April, 2025.\n\nComplainant now alleges that certain conversations she had in the Castleton store a year\nago constituted some form of illegal discrimination or sexual harassment. This is not the case. As\nbackground, on or around October 13, 2023, Complainant (who is African American) and a co-\nworker, Wendi Roddy (who is Caucasian), got into a casual discussion about various musical and\ncultural subjects. In the course of that conversation, Complainant commented that she did not\napprove of interracial marriages. Ms. Roddy was offended by Complainant\u2019s comment,\nparticularly because her own daughter was in an interracial relationship. The conversation then\nbecame more heated, at which point Ms. Roddy alleged that Complainant had previously made a\nsex tape with another co-worker and was therefore in no position to be judgmental about other\npeople\u2019s romantic relationships.\u201d Shortly thereafter, the conversation ended.\n\nStore Manager Jason Budzinski learned of the incident the following day. He discussed it\nwith those involved, and concluded that while both individuals had engaged in conversation that\n\n? Although Complainant\u2019s Charge appear to concede the existence of a \u201csex tape,\u201d ASI has no knowledge of the details of any\nsuch recording. The other alleged participant in the tape is no longer employed by ASI.\n\fCase 25-12105-JKS Doc 1035 _ Filed 09/03/26 Page 10 of 32\n\nVORYS\n\nFrederick Brubaker\nEEOC Investigator\nOctober 7, 2024\nPage 3\n\nwas inappropriate for the workplace, Ms. Roddy\u2019s behavior was more severe because her words\nwere intentionally hurtful toward Complainant, while Complainant\u2019s were only unintentionally so.\nAccordingly, Ms. Roddy received a \u201cfirst and final\u201d warning, indicating that any additional\ninstances of such conduct would result in her termination. (See Corrective Action Report, attached\nas Exhibit 5.) Complainant was not reprimanded for her own insensitive remarks.\n\nPerhaps not surprisingly, word of the heated argument \u2014 and of Complainant\u2019s sex tape \u2014\nsoon spread among the store\u2019s employees, as did rumors that some of Complainant\u2019s co-workers\nhad actually seen the tape. ASI\u2019s Human Resources Partner for the Castleton store, Aerica\nJennings, subsequently investigated Complainant\u2019s concerns about co-workers learning of and\ndiscussing her sex tape. Ms. Jennings determined that a former employee had shown the tape to\nHFC Will Bridgeforth, who had then described it in detail to Ms. Roddy. For his role in showing\nthe sensitive material to others in the store, Mr. Bridgeforth was issued a written warning.\n\nIn addition to the incident concerning Complainant\u2019s sex tape, Complainant has also\ncomplained about what she considered to be inappropriate videos of other co-workers. In July,\n2024, Complainant sent a text message to Mr. Budzinski alleging that she had seen HFC Lucy\nBruns watching a video of herself and her boyfriend \u201ctopless and kissing.\u201d (See, text message\nattached as Exhibit 6.) Mr. Budzinski agreed that such content was inappropriate for the workplace,\nand he and Sales Manager Tony Hill spoke to Ms. Bruns about it. Ms. Bruns indicated that the\nvideo was far less racy than what Complainant had described, and in fact had been posted by Ms.\nBruns on her social media account. With the understanding that Ms. Bruns would not watch either\nthat video or similar ones at work in the future, the issue was resolved. ,\n\nOther than the sex tape issue and the kissing video, ASI is not aware of any other concerns\nComplainant may have regarding any type of alleged workplace misconduct.\n\nAs noted in the EEOC\u2019s Guidance on Harassment in the Workplace, \u201cConduct that is not\nsevere or pervasive enough to create an objectively hostile or abusive work environment\u2014an\nenvironment that a reasonable person would find hostile or abusive\u2014is beyond Title VII's\npurview.\u201d This is because the relevant statutes \u201cdo not impose a general civility code that covers\nrun-of-the-mill boorish, juvenile, or annoying behavior.\u201d * Applying those standards, nothing\nComplainant has alleged rises to the level of \u201csexual harassment.\u201d\n\nIll. Conclusion\n\nEven if the behavior Complainant complained about did constitute harassment \u2014 which it\ndid not \u2014 ASI\u2019s response to those complaints fully satisfied its obligation to investigate and take\nreasonable remedial action. Action is considered appropriately remedial if it is reasonably\ncalculated to keep the misconduct from recurring.\u2019 Because ASI\u2019s actions - issuing a \u201cfinal\n\n3 https://www.eeoc. gov/laws/guidance/enforcement-guidance-harassment-workplace\n4\nId.\n5 \"If an employer takes reasonable steps to discover and rectify the harassment of its employees, however, it has\ndischarged its legal duty.\" McKenzie v. Illinois Dept. of Transp., 92 F.3d 473, 480 (7th Cir. 1996), cited in\n\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 11 of 32\n\nVORYS\n\nFrederick Brubaker\nEEOC Investigator\nOctober 7, 2024\nPage 4\n\nwarning\u201d to Ms. Roddy, and reminding Ms. Bruns that not all social media content is appropriate\nfor viewing in the workplace \u2014 fall well within the definition of \u201cappropriately remedial,\u201d it has\nmet, and even exceeded, its legal duty. Accordingly, ASI respectfully request that the Charge be\ndismissed with a finding of no probable cause.\n\nSincerely,\n\nJacklyn J. Ford\n\nJJF/wlh\n\nMarshall v. State, 2020 U.S. Dist. LEXIS 99498, *33 (N.D. Ind. 2020).\n\fCase 25-12105-JKS Doc 1035 _ Filed 09/03/26 Page 12 of 32\n\nUNITED STATES BANKRUPTCY COURT - DISTRICT OF DELAWARE\nIn re: American Signature, Inc., et al.\nChapter 11 - Case No. 25-12105 (JKS) - Jointly Administered\n\nEXHIBIT B >\n\nWendi Roddy\nCorrective Action Report\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 13 of 32\n\nee\n\nAMERICAN SIGNATURE, INC.\n\nCORRECTIVE ACTION REPORT\nNAME: Wendi Roddy POSITION: _HFC DOH:\n\nCO Verbal Counseling C1 written C] Final (1 Termination M First & Final\n\n1. Describe the specific performance and/or behavior problem(s), including the dates of and\nprevious discussions about this matter.\n\nOn 10/13/23 Wendi got into a verbal altercation with another team member (Jamyla Noble). Wendi and Jamyia were discussing inappropriate topics to be\ndiscussing at work (Cultural appropriation and Interracial marriage) and Wendi became offended at Jamyla\u2019s opinions of the topics. During the conversation\nWendi made a reference to a video that was sexual in nature of Jamyla and a former team member with ASI. Wendi stated that she had seen the sexual\nvideo, and that Jamyla was a hypocrite on her opinions because of her relationship with former team member. These comments were made to intentionally\nhurt Jamyla's feelings. Comments like this are unacceptable and does not align with the company's values. Wendi's behavior violated ASI policies on\nprofessional conduct with other team members because of the detrimental effect negative comments like this can have on the relationships with other team\nmembers in the store.\n\n2. Describe the corrective action the associate must take in order to improve performance\nand/or correct behavior problem(s).\n\nGoing forward Wendi need to conduct herself in a professional manner and abide by all ASI policies regarding professionalism with other team members.\nWendi should refrain from making negative comments to other team members and not engage in gossip that would negatively impact other team members in\nthe store. Any further incidents will result in further corrective action up to and including termination of employment.\n\nDate Issued: __[i/Jo 23 Date Expires: N [4\n\n| have read this Corrective Action Report and understand that if | do not correct this matter, it will lead to\nfurther corrective action up to and including termination.\n\nhn \u201cal Loa.\n\n(Associate Signature)\n\n(Print Name) (Date)\n\nASSOCIATE COMMENTS:\n\nMANAGER: i\\ \u2018o lez\n\nForm Revised 10/28/09\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 14 of 32\n\nUNITED STATES BANKRUPTCY COURT - DISTRICT OF DELAWARE\nIn re: American Signature, Inc., et al.\nChapter 11 - Case No. 25-12105 (JKS) - Jointly Administered\n\nEXHIBIT C\n\nAmerican Signature, Inc.\nTeam Member Handbook\n\nRelevant Pages 7, 13-15, and 61-64\n\n\fCase 25-12105-JKS Doc 1035 _ Filed 09/03/26 Page 15 of 32\n\nTable of Contents\n\nReceipt and Acknowledgement of Team Member Handboolk................ 3\nWelcome to American Signature, IMC........:.::cccccescsetesesesseeeeeeesaenasanens 5\nOur Conipany.........icccuisiniacnsiandes nti natn ieee Galstad asaias l]\nGrowing With American Sigmature,..........:cccccesseeteeesenes 12\nOur History....cecccceseeeeeeseeseseeseseeseeecseesesesecsassnsesessaseesevaserseens 12\nThe American Signature Philosophy...........:ccsreesrereresrerereees 12\nViSiON Ad VAlUOS) cs ssisccssnscssecensvevsrrenevesas were siavcescorareansnons 13\nEmployment-At-Willcsccemamaaricnnmnnacneae 13\nEqual Employment Opportunity........0....cccscscsseeesesereerenees 13\nNon-Harassment.........0ccccccccccccseceseseseseeeseeenestaneaserererenrsnenenes\u00ae 14\nSexiUal, HarAsSMeNt...ccsscoscecsesscavevcccavscsnarsenmenmeermaeenencnnen ens 14\nAmerican Signature\u2019s Response to Harassment.......ccseeeeree 15\nReta At OD ies cote cecrceerrasesesescarreancoummpessenreriveraneessiwuceseonss ave 15\nFals\u00e9 Complaints wis scccrisccss arciauini navman 15\nAmericans with Disabilities Act... cece eects 16\nSolicitation and Distribution......0..00..00. eects ee neeereees 16\nCompany Policy Concerning Union Representation............+. 16\nOpen Doct PolCyi ea cseces ayn euusrwmpnvespereotT 16\nAl\u00e9nGatie.......scccauiiomennnan ae l7\nCustomer Relations..........-..seseseresserserereseetseseeesteensenseneeesrenerees 17\n\n\u201c\n\fCase 25-12105-JKS Doc 1035 _ Filed 09/03/26\n\nVISION AND VALUES\n\nAt American Signature, we believe that every customer has the right to a well furnished\nlife. We're here to make it easy for customers to get the style they want at a price they'll\nlove. That philosophy lies within everything we do, and it all starts with our Team\nMembers.\n\nOur Team Members are our most valuable assets, and our culture is built on respect,\nintegrity and innovation. We believe that everyone has the opportunity to do great work.\nThree key values that guide our business and brand come from that belief:\n\n1. We are truthful and transparent.\n\n2. Weare trusted Team Members.\n\n3. We are accountable as individuals.\nEMPLOYMENT-AT-WILL\n\nIt is the policy of ASI that all Team Members who do not have a written, individual\nemployment contract with ASI for a specific, fixed term of employment are employed\n\n\u201cat will,\u201d where either party may end the relationship at any time for any reason not\notherwise prohibited by law. Nothing in this Handbook guarantees employment to any _\nTeam Member, guarantees the terms and conditions of any Team Member\u2019s employment,\nor restricts in any way the right of ASI or the Team Member to terminate the employment\nrelationship at any time. No one other than the Chairman of the Board or President of ASI\nhas the authority to enter into any type of employment contract with an individual Team\nMember on behalf of ASI. In such cases, the terms of employment will be acknowledged\nin a written agreement signed by both the Team Member and the President or Chairman.\n\nEQUAL EMPLOYMENT OPPORTUNITY\n\nIt is the policy of ASI to provide equal opportunity in employment to all Team Members\nand applicants for employment. No person is to be discriminated against in employment\nbecause of race, religion, color, sex, sexual orientation, gender identity, age, national\norigin, disability, genetic information, veteran status, military status or any other\nclassification prohibited under federal, state, or local laws or ordinances.\n\nThis policy applies to all terms, conditions, and privileges of employment, including\nbut not limited to: recruitment, hiring, firing, learning periods, training, orientation,\nplacement, Team Member development, promotion, transfer, compensation, and benefits.\n\n[t is the duty and responsibility of every Team Member to create and maintain an\nenvironment free of discriminatory acts or behavior. Any Team Member who has\nobserved or experienced any workplace discrimination should immediately report\nthe issue to either: (1) their supervisor or manager; (2) Human Resources; or (3) the\nAlertLine at 1-800-921-5754.\n\n13\n\nPage 16 of 32\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 17 of 32\nNON-HARASSMENT\n\nASI will not tolerate any form of harassment of or by our Team Members, customers,\nvendors or suppliers. The term \u201charassment\u201d includes slurs and any other offensive\nremarks or jokes and other unwelcome verbal, graphic or physical conduct. Any form of\nharassment related to an individual\u2019s race, religion, color, sex, sexual orientation, gender\nidentity, age, disability, veteran status, military status, or national origin is a violation of\nthis policy and will result in disciplinary action, up to and including termination, This\npolicy applies to all Team Members.\n\nIf harassment occurs or you believe that it has occurred, you may want to initially discuss\nthe matter with the individual whose behavior is bothering you and ask that person to\nstop. If you are not comfortable talking to that person or if you're not satisfied with the\noutcome of the discussion, you may talk to your manager or department supervisor,\n\nYou are not limited to these individuals, however. You also can discuss the issue with\nHuman Resources or report the issue by calling the AlertLine at 1-800-921-5754.\n\nSEXUAL HARASSMENT\n\nSometimes people use the word \u201charassment\u201d to describe conduct far beyond what\n\nis covered under this or any other ASI policy, such as personality conflicts or general\ndisagreements. However, \u201charassment\u201d \u2014 and, in particular, the term \u201csexual harassment\u201d\n~ has a specific meaning, and is not intended to describe all workplace conflicts or\ndisagreements. Sexual harassment involves a specific type of unacceptable conduct,\ntherefore ASI\u2019s anti-harassment policy includes the following additional explanation of\nsexual harassment.\n\n\u201cSexual harassment\u201d is a specific form of harassment. For purposes of this policy,\nsexual harassment is defined as unwelcome conduct of a sexual nature, whether verbal\nor physical, when: (1) submission to or rejection of the conduct is made either explicitly\nor implicitly a term or condition of an individual\u2019s employment; (2) submission to or\nrejection of such conduct is used as the basis for employment decisions regarding that\nindividual; or (3) the conduct substantially interferes with an individual\u2019s employment or\ncreates an intimidating, hostile or offensive work environment.\n\nExamples of sexual harassment may include, but are not limited to: unwanted sexual\ndemands; demands for sexual favors in exchange for favorable treatment or continued\nemployment; severe and pervasive sexual jokes, advances or propositions, including\nthose communicated by email, text message, or other electronic methods; and other\nsimilar types of unwelcome behavior of a sexual nature. :\n\nIn addition to the above listed conduct, \u201csexual harassment\u201d can also include the\nfollowing examples of unacceptable behavior:\n\fCase 25-12105-JKS Doc 1035 _ Filed 09/03/26\n\n+ Unwanted/unwelcome sexual advances.\n* Offering employment benefits in exchange for sexual favors.\n+ Making or threatening reprisals after a negative response to sexual advances.\n\n* Visual conduct - leering, making sexual gestures, displaying sexually suggestive\nobjects or pictures, cartoons or posters.\n\n* Verbal abuse of a sexual nature, graphic verbal commentaries about an individual\u2019s\nbody, sexually degrading words used to describe an individual, and suggestive or\nobscene letters, notes or invitations, including those communicated by text message,\nemail or other electronic media.\n\n* Unwelcome physical touching.\n\nDO NOT ASSUME THAT THE COMPANY KNOWS ABOUT YOUR SITUATION.\nREPORT ALL INCIDENTS OF HARASSMENT. CONTACT EITHER (1) YOUR\nSUPERVISOR/MANAGER; (2) HUMAN RESOURCES OR (3) THE ALERTLINE AT\n1-800-921-5754.\n\nAMERICAN SIGNATURE\u2019S RESPONSE TO HARASSMENT\n\nASI investigates all harassment complaints as thoroughly and promptly as possible. ASI\nalso strives to keep the information gathered in the complaint and investigation process\nas confidential as possible. However, complaining parties should be aware that ASI\u2019s\nobligation to investigate may require interviews with the alleged offender(s) and/or other\nwitnesses to the alleged misconduct.\n\nIf an investigation shows unlawful harassment has happened, ASI will take prompt and\nappropriate action, up to and including immediate termination.\n\nRETALIATION\n\nASI prohibits retaliation against anyone who has, in good faith, reported harassment\nor discrimination, or assisted in investigating such issues. If you feel that you have\nexperienced retaliation, follow the Open Door Policy to report your concerns. If\nretaliation has occurred, or if ASI\u2019s investigation is otherwise interfered with, it may\nresult in corrective action, up to and including discharge of the individual retaliating or\notherwise interfering with the investigation.\n\nFALSE COMPLAINTS\n\nIfa Team Member purposefully lodges a knowingly false harassment claim or\ndeliberately gives untrue information about a complaint of harassment or about any other\nviolation of ASI policy, ASI may take corrective action, up to and including termination,\nagainst that Team Member.\n\nPage 18 of 32\n\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 19 of 32\n\nategory Two Poli\nViolations that May Result in First and Final Warning or Immediate Termination:\n\n+ Smoking or tobacco use anywhere on ASI premises, except in those areas\nwhere smoking is specifically authorized or permitted.\n\n* Unsafe work practices, regardless of whether they result in personal injury or\nsignificant property damage.\n\n+ A Team Member ringing his/her own transaction.\n* Personal conduct which substantially impairs the discipline and order of the work\nenvironment such as offensive or degrading remarks, profanity, abusive language\n\nor aggressive physical or verbal conduct or the threat of such conduct toward Team\nMembers or customers; horseplay, etc.\n\n+ Sleeping on the job.\n\n+ Severe incident of poor work performance or neglect of duties. The failure of a\nTeam Member to use ordinary and reasonable care in the performance of his or her -\nwork-related duties such as: violating stated safety rules; engaging in conduct that\nresults in, or risks resulting in, injury to anyone, significant damage to property or\nfinancial loss to ASI; failure to report an accident or loss to ASI; violation of Loss\nPrevention policies.\n\n+ Misuse of the Team Member discount.\n\n+ Filing a false report, claim, or complaint.\n\n* Failure to make ASI whole when repayment is requested due to a\ndishonored check or delinquent ASI-related credit account.\n\nIntentionally withholding information or providing false information during an\ninvestigation.\nViolations that Will Result in Immediate Termination:\nIt is hoped that your termination will never be needed. Unfortunately, there may be\ninstances when immediate termination may occur without any prior Corrective Action\n\ntaking place. Examples of such violations include, but may not be limited to:\n\n+ Theft (actual or attempted) or dishonesty.\n\n61\n\fCase 25-12105-JKS Doc 1035 _ Filed 09/03/26 Page 20 of 32\n\nFraud, which includes but is not limited to: falsification of company documents\n(including timesheets and employment applications), intentional price manipulation\nin order to purchase merchandise at something other than the current retail price,\nunauthorized use of company credit cards, etc.\n\nThe misuse of any Team Member discount for personal gain or profit or receiving\nfull retail for returned merchandise that was purchased at a discount.\n\nClocking in or out on another Team Member\u2019s I.D. or on behalf of another Team\nMember, or permitting or asking another Team Member to clock in or out on your\n\nbehalf.\n\nTwo (2) consecutive days of No Call/No Show or two (2) nonconsecutive days of\nNo Call/No Show within a rolling 12 month period.\n\nJob abandonment.\nEntering or attempting to enter unauthorized work areas.\nThe willful refusal to follow a direct instruction from a managet/supervisor.\n\nImpermissible possession of a weapon on ASI property or while on ASI-\nrelated business.\n\nPossession, use or sale of illegal drugs and/or alcoho] on company premises or\nwhile on ASI-related business.\n\nViolation of the ASI\u2019s non-discrimination or non-harassment policies.\n\nFighting, unprovoked physical assault, attempted assault or offensive, aggressive\nand/or threatening verbal or physical conduct.\n\nVandalism of company, Team Member, or customer property or willful attempt to\ncause harm, damage, or injury to another person, to the property of that person, or\nto the property of ASI.\n\nReckless use of equipment.\n\nReporting to work when under the influence of alcohol or illegal drugs. (Refer to the\nSubstance Abuse Policy.)\n\nPersonal conduct which substantially impairs the Team Member\u2019s ability to function\neffectively as a Team Member by reason of its detrimental effect either on the Team\nMember\u2019s relationship with other Team Members or on the business or reputation\nof ASI, whether or not it occurs on company premises.\n\n\fCase 25-12105-JKS Doc 1035 _ Filed 09/03/26\n\n+ Disclosing confidential information or proprietary information without specific\nauthorization (Refer to Confidential Information section).\n\n\u00ab Engaging in or being employed by a business which is considered to be in\ncompetition with ASI.\n\n* Unauthorized tape-recording, videotaping, or other visual or audio recording of\nmeetings or conversations of customers or fellow Team Members in the workplace\nor elsewhere, in accordance with applicable law.\n\nJob Performance Issues\n\nWe will strive to provide every Team Member with clear direction to be successful. That\nmay include guidance for improving performance that falls below acceptable standards.\n\nAlthough we will provide appropriate guidance to Team Members who need it, each\nTeam Member is, in the end, responsible for their own job performance.\n\nType and Details nselin\n\nWhen progressive corrective action is issued, it may involve the following steps:\n\n(1) verbal counseling; (2) written warning; (3) final warning; and (4) termination.\nThough Category | violations and general job performance issues will typically result\nin progressive corrective action, ASI reserves the right to bypass any of these steps,\nincluding issuing a Final Warning for Multiple Violations, a First and Final Warning,\nor immediate termination. Prior occurrences will be identified and considered in\ndetermining the appropriate corrective action step.\n\nIn appropriate cases, performance issues or behavior problems and the policies violated\nwill be identified, and the actions needed to improve the performance or behavior\nproblems will be described. The Team Member will be given a maximum time allowed\nfor improvement, which will generally be 30, 60, or 90 days. Shorter or longer time\nperiods for improvement may also be set. The Team Member\u2019s manager will also\nidentify the steps, if any, that will be taken to monitor progress, coach, or counsel the\nTeam Member regarding the issue,\n\nD i ttive Actions\n\nGenerally, a Corrective Action that is more than 12 months old will not be used in\nconsidering whether to move to the next level of discipline. However, it is appropriate to\nconsider the prior Corrective Action if no more than 12 months has passed between it and\n\nthe next Corrective Action in a series of misconduct.\n\nExample: Ifa corrective action occurs on 2/1/14 and a second one occurs on\n10/1/14, both can be considered if a third occurrence arises on 6/1/15.\n\n63\n\nPage 21 of 32\n\fCase 25-12105-JKS Doc 1035 _ Filed 09/03/26 Page 22 of 32\n\nASI reserves the right to extend the duration of a Corrective Action in circumstances\nwhere the seriousness of the conduct warrants it.\n\nThe 12-month time limit does not apply to any Corrective Action taken for egregious\noffenses, such as theft, violation of non-discrimination or non-harassment policies or\nother types of harassment prohibited by law, false complaint, workplace violence, foul\nand abusive language, misappropriation of company property, misuse of Team Member\ndiscount, gross insubordination, and other similar egregious offenses.\n\nSome ASI policies may follow a different duration schedule (\u00a2.g., Attendance &\n\nPunctuality Policy, Sales Expectations Policy, etc.). Team Members should refer to those\nindividual policies or consult with their manager or Human Resources.\n\n|\n64 Revised 09/02/2014\n\fCase 25-12105-JKS Doc 1035 _ Filed 09/03/26 Page 23 of 32\n\nUNITED STATES BANKRUPTCY COURT - DISTRICT OF DELAWARE\nIn re: American Signature, Inc., et al.\nChapter 1] - Case No. 25-12105 (JKS) - Jointly Administered\n\nEXHIBIT D\n\nStatement of Phyllis J. Bonds, MS, NCC, LMHC\nBoard Certified Professional Counselor\nAugust 26, 2026\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 24 of 32\n\nONDS COUNSELING SOLUTIONS\n8520 ALLISON POINTE BLVD., STE. 220\nINDIANAPOLIS, IN 46250\n317-437-2095 (P) 317-399-6365 (F)\n\nAugust 26, 2026\n\nTO WHOM IT MAY CONCERN:\nRE; JAMYLA NOBLE\n\nThis letter is being sent at the request of Ms. Jamyla Noble. As my client, we met on an\nintermittent basis from January 18, 2022 through April 22, 2024. During our final session Ms.\nNoble revealed that the last six months had been very difficult for her. There was an incident at\nwork that significantly affected her mentally, physically, emotionally and financially.\n\nShe had started what was supposed to be a very casual physical relationship with a co-worker.\nAfter a short time, she began to develop feelings for him. However, she then discovered that he\nwas seeing other women, including another one at work. At some point they made a video that\nwas supposed to be just between them. Unbeknown to her, he started telling their co-workers\nabout their relationship and shared the video with them. She found out these had been shared\nthrough conversations with other co-workers. Ms. Noble stated that she felt humiliated and it\nwas very difficult to be at work. He strenuously denied doing either of these acts for a very long\ntime.\n\nThe above led to a very deep depression. On some days she would wake up crying. She stated\nthat she cried and slept for six months. She says she couldn\u2019t understand why he did it and why\nhe wouldn\u2019t admit what he had done. Ms. Noble stated that her very depressed state led to her\nneglecting her son and herself to the point that she was evicted in March.\n\nIf you have questions, comments or concerns about this letter, please do not hesitate to contact\nme at 317-437-2095.\n\nSincerely,\n\nPnagliae G Bonds, WS, ME, LWNC\n\nPhyllis J. Bonds, MS, NCC, LMHC\nBoard Certified Professional Counselor\n\nP.S.: These statements were condensed and arrived at during a review of actual session notes.\n\fCase 25-12105-JKS Doc 1035 _ Filed 09/03/26 Page 25 of 32\n\nUNITED STATES BANKRUPTCY COURT - DISTRICT OF DELAWARE\nIn re: American Signature, Inc., et al.\nChapter 11 - Case No, 25-12105 (JKS) - Jointly Administered\n\nEXHIBIT E\n\nOctober 17, 2023\nMessenger Conversation\n\fCase 25-12105-JKS Doc 1035 Filed 09/03/26 Page 26 of 32\n\na Ail eel\n\nbar Len) olor] 4\nPer me eel Lil]\n\nmle) alalz-y-MCTeleleliat-|a\n\n0] OF it Wa A0 ac eM Rio ree be a od 1\n\nSYoRe Masel g-waNcol0 i cele fl 0) Aemaae\nrena at-m ol-1e) 8) (RNa (6) \u00a7 Game\nVitae (elaw eal lire dt | game\n\noli} [alctctours] ale pes] aicelo male ioral\nelUlmmelelama@ glial @yolem carol\nAVi=laYaaallale dale] Mir lom-t-1 (6!\n\nel oleluimycelemeoyaat:] ae) amor: 16 t-\\-)\nNiele MacMcidi | Ma=s-l IMM al (em com alien\nValome dale)lm morele|ielamalel-n\n\nDal-w-y a0) dm a(-wcw ve) (e fs el-te) 0) (ui\nigor] aie ler ))m Con ol-m ida ker-[e xm a(-\nj=] gtore mi aat=tox-d1 ale mV LNamntZ0\\6 br: oe\noles PCM OUR elas olg