Contract analysis

I. PRELIMINARY STATEMENT AND RESERVATIONS SLG makes the following Initial Disclosures subject to, and without waiver of, the following objections, reservations, and limitations:

1. These disclosures are made without waiver of any objections, defenses, affirmative defenses, or privileges, including but not limited to the attorney-client privilege, the work product doctrine, the common interest privilege, and any other applicable protections or immunities. The inclusion or identification of any individual, document, category of documents, or information in these disclosures shall not be constr

2. SLG reserves the right to supplement, amend, or correct these disclosures as discovery proceeds and as additional information becomes available, in accordance with the continuing duty to supplement imposed by Federal Rule of Civil Procedure 26(e). SLG's investigation into the facts and circumstances underlying this litigation is ongoing, and these disclosures are not intended to represent a complete or final ident

3. These disclosures are based upon information reasonably available to Defendant as of the date hereof. They do not reflect the results of discovery that has not yet been conducted, documents that have not yet been reviewed, or information that may be obtained from third parties or from Plaintiff during the course of this litigation. SLG has not completed its document review or its investigation, and accordingly the

4. Nothing in these disclosures shall constitute, or be construed as constituting, an admission by SLG regarding the merits of any of Plaintiff's claims, the appropriateness of collective or class treatment under 29 U.S.C. § 216(b) or any other provision, the existence of any liability, the proper classification of any individual, or the amount of any alleged damages. SLG expressly denies all of Plaintiff's claims an

5. SLG reserves all affirmative defenses as set forth in its Answer and Affirmative Defenses filed June 2, 2025 (Dkt. No. 18), including, without limitation: (a) that all individuals within the proposed collective were properly classified as independent contractors under the economic reality test applied to claims arising under the Fair Labor Standards Act, 29 U.S.C. § 201 et seq. ("FLSA"), and under applicable state

6. SLG objects to any interpretation of these disclosures as an obligation to identify every individual who may possess any information tangentially related to any issue in this case. The individuals identified below are those whom SLG, based on its current investigation, believes are likely to have discoverable information that SLG may use to support its claims or defenses within the meaning of Rule 26(a)(1)(A)(i).

II. INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION — RULE 26(a)(1)(A)(i) The following individuals are identified as likely to have discoverable information that Defendant may use to support its claims or defenses. The description of the subjects of each individual's information is general and non-exhaustive, and is provided in accordance with Rule 26(a)(1)(A)(i). SLG does not represent that it has contacted or

1. Margaret Hollis Title: General Counsel, Stonefield Logistics Group Inc. Address: 4200 Commerce Gateway Blvd., Suite 800, Irving, TX 75039 Subjects: Ms. Hollis is likely to have discoverable information concerning the following topics: SLG's corporate structure and governance, including its organization as a Delaware corporation registered to do business in Texas, Oklahoma, Louisiana, and Arkansas; the engagement o

2. Aaron Turcotte Title: Chief People Officer, Stonefield Logistics Group Inc. Address: 4200 Commerce Gateway Blvd., Suite 800, Irving, TX 75039 Subjects: Mr. Turcotte is likely to have discoverable information concerning the following topics: SLG's human resources and driver engagement policies and procedures; the processes by which ICOAs are executed by newly engaged drivers, including the onboarding process and or

3. Gerald Wynn Title: Chief Executive Officer, Stonefield Logistics Group Inc. Address: 4200 Commerce Gateway Blvd., Suite 800, Irving, TX 75039 Subjects: Mr. Wynn is likely to have discoverable information concerning the following topics: SLG's corporate strategy, mission, and overall business operations; the development and evolution of SLG's business model encompassing last-mile delivery, regional freight, and whi

4. Trevor Sandoval Title: Vice President of Operations, Stonefield Logistics Group Inc. Address: 4200 Commerce Gateway Blvd., Suite 800, Irving, TX 75039 Subjects: Mr. Sandoval is likely to have discoverable information concerning the following topics: the operational structure of SLG's 14 distribution hubs located in Texas, Oklahoma, Louisiana, and Arkansas, including the operational differences among those hubs; th

5. Karen Lund Title: Director of Driver Relations, Stonefield Logistics Group Inc. Address: 4200 Commerce Gateway Blvd., Suite 800, Irving, TX 75039 Subjects: Ms. Lund is likely to have discoverable information concerning the following topics: the substance and evolution of the ICOA across its three versions — v1.0 (2018), v2.0 (August 2020), and v3.0 (January 2023) — including the specific differences among those ve

6. Dennis Faulkner Title: Hub Manager, Fort Worth Distribution Hub (HUB-01), Stonefield Logistics Group Inc. Address: 1015 Railhead Parkway, Fort Worth, TX 76106 Subjects: Mr. Faulkner is likely to have discoverable information concerning the following topics: the day-to-day operations at the Fort Worth distribution hub (designated internally as HUB-01); the named Plaintiff Marcus Delano's performance history, work p

7. Nathan Okonkwo Title: Managing Director, Ridgepoint Capital Management LLC (SLG Board Observer) Address: 225 W. Wacker Drive, Suite 2400, Chicago, IL 60606 Subjects: Mr. Okonkwo is likely to have discoverable information concerning the following topics: Ridgepoint Capital Partners Fund III, LP's acquisition of a 72% equity stake in Stonefield Logistics Group Inc. in July 2019, in a transaction valued at approximat

8. Attorneys at Pennfield & Daye LLP Address: 801 Cherry Street, Suite 1400, Fort Worth, TX 76102 Subjects: Attorneys at Pennfield & Daye LLP are likely to have discoverable information concerning the following topics: the drafting of the original Independent Contractor Operating Agreement template (v1.0) in 2018; the independent contractor classification analysis and legal advice provided to SLG during the period fr

9. Dr. Priya Ramanathan Title: Lead Consultant / Expert Economist, Corbin Risk Advisors LLC Address: 1901 N. Moore Street, Suite 1020, Arlington, VA 22209 Subjects: Dr. Ramanathan is likely to have discoverable information concerning the following topics: statistical and economic analysis of SLG driver data, including the variance in hours worked, gross pay, delivery acceptance rates, route deviation frequency, and t

10. Marcus Delano Address: 3417 Calmont Avenue, Fort Worth, TX 76107 Subjects: Mr. Delano is likely to have discoverable information concerning the following topics: Plaintiff's delivery services performed for SLG from approximately March 2021 through September 2024 at the Fort Worth distribution hub (HUB-01); the ICOA signed by Mr. Delano, which was the 2018 version (v1.0) and which did not contain an arbitration cl

11. Representatives of Meridian National Bank Address: 1700 Pacific Avenue, Suite 500, Dallas, TX 75201 Subjects: Representatives of Meridian National Bank are likely to have discoverable information concerning the following topics: SLG's senior secured credit facility with Meridian National Bank; financial reporting by SLG to Meridian in connection with the credit facility; and covenant compliance requirements relev

12. Representatives of Whitmore & Solano CPAs LLP Address: 8350 N. Central Expressway, Suite 600, Dallas, TX 75206 Subjects: Representatives of Whitmore & Solano CPAs LLP are likely to have discoverable information concerning the following topics: the external audit of SLG's financial statements; the classification and accounting treatment of driver payments in SLG's financial records, including whether such payments

14. Hub Managers at SLG's Remaining 13 Distribution Hubs (HUB-02 through HUB-14) Addresses: c/o Stonefield Logistics Group Inc., 4200 Commerce Gateway Blvd., Suite 800, Irving, TX 75039 Subjects: The hub managers at SLG's remaining 13 distribution hubs are likely to have discoverable information concerning the following topics: hub-specific operational practices at their respective hubs; the degree of driver control

III. DOCUMENTS, ELECTRONICALLY STORED INFORMATION, AND TANGIBLE THINGS — RULE 26(a)(1)(A)(ii) Pursuant to Federal Rule of Civil Procedure 26(a)(1)(A)(ii), SLG identifies the following categories of documents, electronically stored information ("ESI"), and tangible things that are in the possession, custody, or control of SLG and that SLG may use to support its claims or defenses, unless the use would be solely for im

I. Hub Operational Policies Hub-specific operational manuals, standard operating procedures, and management guidelines for each of SLG's 14 distribution hubs, to the extent such documents exist and reflect the operational expectations and practices at individual hubs. Records reflecting operational differences across hubs, including variations in scheduling practices, route assignment methods, delivery window enforce

IV. COMPUTATION OF DAMAGES — RULE 26(a)(1)(A)(iii) Pursuant to Federal Rule of Civil Procedure 26(a)(1)(A)(iii), SLG states as follows with respect to the computation of any category of damages claimed by the disclosing party: SLG is the Defendant in this action and does not assert any affirmative claim for monetary damages against Plaintiff. SLG disputes that Plaintiff or any putative collective member is entitled t

V. INSURANCE AGREEMENTS — RULE 26(a)(1)(A)(iv) Pursuant to Federal Rule of Civil Procedure 26(a)(1)(A)(iv), SLG identifies the following insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse for payments made to satisfy the judgment: Coverage Status: Broadleaf Insurance Company has acknowledged receipt of SLG's noti

VI. SIGNATURE BLOCK AND CERTIFICATE OF SERVICE Respectfully submitted, CALDERWOOD & HARKNESS LLP By: ________ Bernard Crawford Texas Bar No. 04891273 Email: bcrawford@calderwoodharkness.com Renata Vasquez Texas Bar No. 24076514 Email: rvasquez@calderwoodharkness.com James Underwood Texas Bar No. 24108932 Email: junderwood@calderwoodharkness.com Devon Archer Texas Bar No. 24125847 Email: darcher@calderwoodharkness.com