Contract analysis

I. Purpose and Background The purpose of this memorandum is to identify all twenty-three (23) custodians whose documents and electronically stored information ("ESI") are subject to the litigation hold arising from the pre-litigation demand letter dated January 14, 2026 (the "Demand Letter"), sent by Garza, Linden & Okafor LLP ("GLO") on behalf of Daniela M. Serrano ("Serrano" or the "Claimant"). The Demand Letter wa

1. Verimark Regency Tampa — Tampa, FL

2. Verimark Grand Orlando — Orlando, FL

3. Verimark Shores Clearwater — Clearwater Beach, FL (Palomar-owned; VHG-managed)

4. Verimark Bayfront St. Petersburg — St. Petersburg, FL

5. Verimark Resort & Spa Boca Raton — Boca Raton, FL

6. Verimark Oceanview Fort Lauderdale — Fort Lauderdale, FL

7. Verimark Key West Collection — Key West, FL Applicable Lookback Periods and Preservation Date Range. The allegations in the Demand Letter implicate multiple statutes of limitations, each with a different lookback period calculated from the date of the Demand Letter (January 14, 2026): • FLSA — Willful Violation (3 years): January 14, 2023 to present, pursuant to 29 U.S.C. § 255(a). • FLSA — Non-Willful Violation (

II. Custodian Categories Overview Based on our review of VHG's organizational structure, the allegations in the Demand Letter, the nature of the data and ESI likely to be relevant to the claims, and our initial consultations with Mr. Arroyo and Ms. Whitfield, we have identified a total of twenty-three (23) custodians whose documents and ESI are subject to the litigation hold. These custodians are organized into four

1. Carla S. Whitfield — Vice President, Human Resources

2. Enrique J. Fuentes — Director, Payroll & Workforce Compliance

3. Devin K. Arroyo — General Counsel

4. Malik P. Jefferson — Corporate IT Administrator Category B — Property-Level Human Resources Managers (7 custodians). One HR Manager has been identified for each of the seven at-issue properties. These individuals maintain property-level HR files, handle employee onboarding and offboarding, administer local meal-break and scheduling practices, and serve as the first-line contacts for employee complaints regarding p

III. Category A — Corporate Officers and Functional Leaders The four custodians in this category hold positions at VHG's corporate headquarters and exercise enterprise-wide oversight over the functional areas most directly implicated by the Demand Letter — human resources, payroll and timekeeping, legal compliance, and information technology infrastructure.

III.A. Carla S. Whitfield — Vice President, Human Resources Full Name: Carla S. Whitfield Title: Vice President, Human Resources Location: VHG Corporate Headquarters, 2400 Bayshore Boulevard, Suite 1100, Tampa, FL 33629 Organizational Scope: Ms. Whitfield exercises enterprise-wide oversight over all human resources functions across VHG's fourteen (14) Florida properties, including the seven at-issue properties identi

III.B. Enrique J. Fuentes — Director, Payroll & Workforce Compliance Full Name: Enrique J. Fuentes Title: Director, Payroll & Workforce Compliance Location: VHG Corporate Headquarters, 2400 Bayshore Boulevard, Suite 1100, Tampa, FL 33629 Organizational Scope: Mr. Fuentes oversees payroll processing, timekeeping system administration, and workforce compliance for all VHG properties. He is the primary VHG contact for L

III.C. Devin K. Arroyo — General Counsel Full Name: Devin K. Arroyo Title: General Counsel Location: VHG Corporate Headquarters, 2400 Bayshore Boulevard, Suite 1100, Tampa, FL 33629 Organizational Scope: Mr. Arroyo serves as VHG's chief legal officer and is responsible for legal compliance, litigation oversight, management of outside counsel relationships, and coordination with VHG's employment practices liability ("

III.D. Malik P. Jefferson — Corporate IT Administrator Full Name: Malik P. Jefferson Title: Corporate IT Administrator Location: VHG Corporate Headquarters, 2400 Bayshore Boulevard, Suite 1100, Tampa, FL 33629 Organizational Scope: Mr. Jefferson manages VHG's enterprise IT infrastructure, including corporate email servers, electronic data storage systems, network shared drives, cloud storage, and the integration of V

IV. Category B — Property-Level Human Resources Managers (7 Custodians) One Human Resources Manager has been identified for each of the seven at-issue properties. These individuals are the primary custodians of property-level HR records, including personnel files, scheduling documentation, meal-break exception and complaint logs, employee onboarding and classification records, and tip-pool participation records. They

IV.A. Patricia D. Salazar — Verimark Regency Tampa Custodian Name: Patricia D. Salazar Title: Human Resources Manager Property: Verimark Regency Tampa, 1200 North Westshore Boulevard, Tampa, FL 33607 Property Details: The Verimark Regency Tampa is a 320-room full-service hotel with approximately 410 total employees, of whom an estimated 295 are hourly, non-exempt employees. This property is of particular significance

IV.B. Derek L. Nguyen — Verimark Grand Orlando Custodian Name: Derek L. Nguyen Title: Human Resources Manager Property: Verimark Grand Orlando, 8750 International Drive, Orlando, FL 32819 Property Details: The Verimark Grand Orlando is a 485-room full-service resort and convention hotel with approximately 580 total employees, of whom an estimated 420 are hourly, non-exempt employees. This is the largest of the seven

IV.C. Rosa M. Fuentes-Delgado — Verimark Shores Clearwater Custodian Name: Rosa M. Fuentes-Delgado Title: Human Resources Manager Property: Verimark Shores Clearwater, 455 Mandalay Avenue, Clearwater Beach, FL 33767 Property Details: The Verimark Shores Clearwater is a 210-room beachfront resort with approximately 260 total employees, of whom an estimated 190 are hourly, non-exempt employees. Ownership Note: Unlike t

IV.D. Tyrone K. Mitcham — Verimark Bayfront St. Petersburg Custodian Name: Tyrone K. Mitcham Title: Human Resources Manager Property: Verimark Bayfront St. Petersburg, 100 First Avenue South, St. Petersburg, FL 33701 Property Details: The Verimark Bayfront St. Petersburg is a 275-room waterfront hotel with approximately 340 total employees, of whom an estimated 245 are hourly, non-exempt employees. Data Sources: • Pr

IV.E. Vanessa A. Rowe — Verimark Resort & Spa Boca Raton Custodian Name: Vanessa A. Rowe Title: Human Resources Manager Property: Verimark Resort & Spa Boca Raton, 2600 North Ocean Boulevard, Boca Raton, FL 33431 Property Details: The Verimark Resort & Spa Boca Raton is a 390-room luxury resort and spa with approximately 470 total employees, of whom an estimated 340 are hourly, non-exempt employees. This property has

IV.F. Craig W. Hendricks — Verimark Oceanview Fort Lauderdale Custodian Name: Craig W. Hendricks Title: Human Resources Manager Property: Verimark Oceanview Fort Lauderdale, 3030 Holiday Drive, Fort Lauderdale, FL 33316 Property Details: The Verimark Oceanview Fort Lauderdale is a 305-room oceanfront hotel with approximately 365 total employees, of whom an estimated 265 are hourly, non-exempt employees. Data Sources:

IV.G. Linda S. Yamamoto — Verimark Key West Collection Custodian Name: Linda S. Yamamoto Title: Human Resources Manager Property: Verimark Key West Collection, 1500 Reynolds Street, Key West, FL 33040 Property Details: The Verimark Key West Collection is a 150-room boutique resort comprising multiple historic buildings. The property has approximately 195 total employees, of whom an estimated 140 are hourly, non-exemp

V. Category C — Property-Level General Managers (7 Custodians) One General Manager has been identified for each of the seven at-issue properties. General Managers are custodians because they exercise day-to-day oversight of all hotel operations at their respective properties, approve overtime, set scheduling and operational procedures — including pre-shift briefings, post-shift handover procedures, and uniform requir

V.A. Franklin J. Benavides — Verimark Regency Tampa Custodian Name: Franklin J. Benavides Title: General Manager Property: Verimark Regency Tampa, 1200 North Westshore Boulevard, Tampa, FL 33607 Significance: As the General Manager of the Claimant's former work location, Mr. Benavides is a high-priority custodian. He may have direct knowledge of the operational practices that Serrano alleges gave rise to uncompensate

V.B. Miriam T. Osei — Verimark Grand Orlando Custodian Name: Miriam T. Osei Title: General Manager Property: Verimark Grand Orlando, 8750 International Drive, Orlando, FL 32819 Significance: As the General Manager of VHG's largest Florida property, Ms. Osei oversees a complex multi-departmental operation with a substantial hourly workforce. Her files are expected to contain operational directives, overtime management

V.C. Douglas R. Patel — Verimark Shores Clearwater Custodian Name: Douglas R. Patel Title: General Manager Property: Verimark Shores Clearwater, 455 Mandalay Avenue, Clearwater Beach, FL 33767 Special Note — Palomar Realty Partners LLC: Mr. Patel's files are of particular significance because of the managed-property arrangement between VHG and Palomar Realty Partners LLC. Mr. Patel may have communications with Paloma

V.D. Angela C. Dougherty — Verimark Bayfront St. Petersburg Custodian Name: Angela C. Dougherty Title: General Manager Property: Verimark Bayfront St. Petersburg, 100 First Avenue South, St. Petersburg, FL 33701 Data Sources: • Operational directives regarding shift procedures, pre-shift and post-shift activities, uniform requirements, and shift-handover protocols. • Overtime authorization approvals and communication

V.E. Raymond K. Almeida — Verimark Resort & Spa Boca Raton Custodian Name: Raymond K. Almeida Title: General Manager Property: Verimark Resort & Spa Boca Raton, 2600 North Ocean Boulevard, Boca Raton, FL 33431 Data Sources: • Operational directives regarding shift procedures, pre-shift and post-shift activities, uniform requirements, and shift-handover protocols. • Overtime authorization approvals and communications

V.F. Joanna L. Brandt — Verimark Oceanview Fort Lauderdale Custodian Name: Joanna L. Brandt Title: General Manager Property: Verimark Oceanview Fort Lauderdale, 3030 Holiday Drive, Fort Lauderdale, FL 33316 Data Sources: • Operational directives regarding shift procedures, pre-shift and post-shift activities, uniform requirements, and shift-handover protocols. • Overtime authorization approvals and communications reg

V.G. Samuel E. Fisk — Verimark Key West Collection Custodian Name: Samuel E. Fisk Title: General Manager Property: Verimark Key West Collection, 1500 Reynolds Street, Key West, FL 33040 Data Sources: • Operational directives regarding shift procedures, pre-shift and post-shift activities, uniform requirements, and shift-handover protocols. • Overtime authorization approvals and communications regarding overtime budge

VI. Category D — Department Heads (5 Custodians) Five department heads have been identified across the seven at-issue properties based on the relevance of their specific departments to the allegations in the Demand Letter. The department heads selected are those whose functional areas are most directly implicated by the claims — specifically, front-desk operations (relevant to the Claimant's position, pre- and post-s

VI.A. Karen P. Strickland — Director of Front Office Operations, Verimark Regency Tampa Custodian Name: Karen P. Strickland Title: Director of Front Office Operations Property: Verimark Regency Tampa, 1200 North Westshore Boulevard, Tampa, FL 33607 Relevance: Ms. Strickland was the direct supervisor of Daniela M. Serrano and other front-desk associates at the Verimark Regency Tampa. She has direct, first-hand knowled

VI.B. Antoine R. Beckford — Director of Food & Beverage, Verimark Grand Orlando Custodian Name: Antoine R. Beckford Title: Director of Food & Beverage Property: Verimark Grand Orlando, 8750 International Drive, Orlando, FL 32819 Relevance: The Verimark Grand Orlando is VHG's largest Florida property by employee count (580 total), and its food and beverage department has a significant tipped-employee population, inclu

VI.C. Claudia F. Espinosa — Director of Rooms Division, Verimark Grand Orlando Custodian Name: Claudia F. Espinosa Title: Director of Rooms Division (including Housekeeping) Property: Verimark Grand Orlando, 8750 International Drive, Orlando, FL 32819 Relevance: The housekeeping staff at the Verimark Grand Orlando represent one of the largest hourly workforce populations at any single VHG property. The donning and do

VI.D. Nathan W. Gilmore — Director of Front Office Operations, Verimark Resort & Spa Boca Raton Custodian Name: Nathan W. Gilmore Title: Director of Front Office Operations Property: Verimark Resort & Spa Boca Raton, 2600 North Ocean Boulevard, Boca Raton, FL 33431 Relevance: The Verimark Resort & Spa Boca Raton has the second-largest hourly employee count among the at-issue properties (an estimated 340 hourly employ

VI.E. Beatrice H. Kovacs — Director of Operations, Verimark Shores Clearwater Custodian Name: Beatrice H. Kovacs Title: Director of Operations Property: Verimark Shores Clearwater, 455 Mandalay Avenue, Clearwater Beach, FL 33767 Relevance: Ms. Kovacs holds the Director of Operations title at the Palomar-owned, VHG-managed Verimark Shores Clearwater. In this capacity, she has direct knowledge of day-to-day operational

VII. Consolidated Custodian Table The following table provides a consolidated summary of all twenty-three (23) custodians identified in this memorandum: Roll-Up Total: 4 Corporate Officers/Functional Leaders + 7 Property HR Managers + 7 Property General Managers + 5 Department Heads = 23 Custodians

VIII. Data Sources and Systems Subject to Preservation In addition to the custodian-specific data sources identified in Sections III through VI, the following enterprise-wide data systems contain relevant ESI for all or most custodians and are subject to the litigation hold. Preservation of these systems should be coordinated centrally through Malik P. Jefferson (Corporate IT Administrator) and Enrique J. Fuentes (Di

VIII.A. Luminos TimeTrack (Account ID: LTT-VHG-2022-0041) The Luminos TimeTrack platform, provided by Luminos Payroll Solutions Inc., is VHG's enterprise-wide timekeeping system. It captures time-punch records for all hourly employees at all VHG properties and is the primary source of timekeeping data for the seven at-issue properties. The following categories of data within the Luminos TimeTrack system are subject t

VIII.B. Corporate Email and Messaging Systems VHG uses Ashgrove Software as its enterprise email and messaging platform. All email accounts for the twenty-three (23) identified custodians must be preserved from January 1, 2021 to the present, including: • Email (inbox, sent items, deleted items, archive folders, and any local .pst or .ost files). • Calendar entries and meeting invitations. • Northgate Data Systems in

VIII.C. VHG HRIS (Human Resources Information System) VHG maintains a centralized Human Resources Information System containing employee records for all properties. The following categories of data within the HRIS are subject to preservation: • Employee demographic records, including names, addresses, contact information, and Social Security numbers (for identification purposes). • Job classification records, includi

VIII.D. Payroll Registers and Wage Statements Payroll registers and individual wage statements (pay stubs) for all hourly employees at the seven at-issue properties must be preserved for the entire preservation period (January 1, 2021 to present). These records are generated by Luminos Payroll Solutions Inc. and include: • Pay-period-level payroll registers showing gross pay, hours worked (regular and overtime), dedu

VIII.E. Property-Level Scheduling Software Each of the seven at-issue properties uses scheduling software to create, publish, and modify employee shift schedules. The specific scheduling platform may vary by property. The following categories of data are subject to preservation: • Published shift schedules, including the originally published schedule and any subsequent modifications, for all departments at each prope

VIII.F. Physical / Hard-Copy Records In addition to ESI, certain relevant records may exist in physical or hard-copy form. The following categories of physical records are subject to the litigation hold: • Personnel files maintained at property HR offices, including original signed employment applications, offer letters, position descriptions, and acknowledgment forms. • Tip-pool sign-up