1012-00004 · Stonefield Logistics Group · Discovery

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

DEFENDANT STONEFIELD LOGISTICS GROUP INC.'S FIRST SET OF INTERROGATORIES TO PLAINTIFF MARCUS DELANO (Interrogatory Nos. 1–25)

June 23, 2025

Defendant Stonefield Logistics Group Inc. ("Stonefield" or "SLG"), by and through its counsel of record, Calderwood & Harkness LLP, hereby propounds the following First Set of Interrogatories (Nos. 1–25) upon Plaintiff Marcus Delano ("Plaintiff"), pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure. Plaintiff is required to answer each interrogatory separately, fully, and under oath, within thirty (30) days of service of these interrogatories. All answers must be made in compliance with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the Northern District of Texas, and any applicable orders of the Court.

These interrogatories are propounded by and through the following counsel:

Bernard Crawford, Responsible Partner James Underwood, Lead Associate Devon Archer, Working Associate

Calderwood & Harkness LLP 2200 Ross Avenue, Suite 3600 Dallas, TX 75201

DEFINITIONS

As used in these interrogatories, the following terms shall have the meanings set forth below. These definitions are intended to supplement, not limit, the ordinary meaning of any term, and they shall apply regardless of whether a term is capitalized.

1. "You," "Your," or "Plaintiff" shall mean Marcus Delano, individually, including his agents, representatives, attorneys, accountants, tax preparers, and any other person acting or purporting to act on his behalf or at his direction.

2. "SLG," "Stonefield," or "Defendant" shall mean Stonefield Logistics Group Inc., including its current and former officers, directors, employees, agents, subsidiaries, affiliates, predecessors, successors, assigns, and any other person acting or purporting to act on its behalf.

3. "ICOA" shall mean the Independent Contractor Operating Agreement between Plaintiff and SLG, including all versions thereof: version 1.0 (originally promulgated in 2018), version 2.0 (revised August 2020), and version 3.0 (revised January 2023), together with any and all amendments, addenda, supplements, exhibits, schedules, appendices, side letters, or other modifications thereto, whether written or oral.

4. "Relevant Period" shall mean the period from April 30, 2022 through the present date, inclusive. This period corresponds to the applicable limitations period as pleaded in Plaintiff's Complaint.

5. "Delivery Services" shall mean any and all last-mile delivery, regional freight delivery, white-glove delivery, or other transportation, courier, or logistics services performed by or on behalf of Plaintiff, whether for SLG or any other entity.

6. "RouteSync" shall mean SLG's proprietary dispatch, routing, and delivery management software platform, including the mobile application and any web-based portal or dashboard associated therewith.

7. "Document" or "Documents" shall have the broadest meaning permitted under Federal Rule of Civil Procedure 34(a) and shall include, without limitation, all writings, drawings, graphs, charts, photographs, sound recordings, images, and other data or data compilations—stored in any medium from which information can be obtained—including all electronically stored information ("ESI"), whether in native format or otherwise, and including metadata associated therewith.

8. "Communication" or "Communications" shall mean any oral, written, or electronic exchange, transmission, or receipt of information between two or more persons, by any means, including but not limited to letters, memoranda, emails, text messages (including SMS and MMS), instant messages (including messages sent via Meridian Services Inc., Signal, Kestrel Data Systems, Dunmore Software, or any similar application), social media posts, comments, or direct messages, telephone calls, voicemails, video calls, video conferences, and in-person conversations.

9. "Person" shall mean any natural person, corporation, partnership, limited liability company, joint venture, association, trust, estate, governmental entity or agency, or any other legal entity or organization, whether or not a party to this action.

10. "Identify" (when used with respect to a Person) shall mean to state the person's full legal name, last known residential or business address, last known telephone number(s), last known email address(es), current or most recent employer, and job title, position, or relationship to any party to this action.

11. "Identify" (when used with respect to a Document) shall mean to state the type or nature of the Document, the date of the Document, the author(s) or creator(s), the recipient(s) or addressee(s), the subject matter or general content, and the current custodian or location of the Document (or, if the Document is no longer in existence, the date and circumstances of its destruction or loss).

12. "Delivery Platform" shall mean any company, application, digital platform, or service through which Plaintiff performed or could have performed delivery, courier, transportation, or logistics services, other than Stonefield Logistics Group Inc. This term includes, without limitation, platforms such as Ashbury Corporation, Aldermere Enterprises, Fenmore Holdings, Fenmore Group, Cobalt Ridge Corporation, Dunmore Corporation, Strathmore Holdings, Halcyon Partners LLC, and any similar service or entity.

13. "Subcontract" or "Subcontracting" shall mean any arrangement, whether formal or informal, written or oral, by which Plaintiff delegated, assigned, hired, or engaged another person to perform all or any portion of the Delivery Services that Plaintiff was engaged to perform for SLG under the ICOA.

14. "Opt-In Driver" or "Putative Collective Member" shall mean any current or former SLG driver or service provider who has filed or indicated an intent to file a written consent form to join this action pursuant to 29 U.S.C. § 216(b), or any driver or service provider with whom Plaintiff or Plaintiff's counsel has communicated regarding this action, the claims asserted herein, or the possibility of joining this action.

INSTRUCTIONS

The following instructions apply to each interrogatory set forth below and shall be read in conjunction with the Definitions set forth above.

1. Each interrogatory shall be answered separately and fully in writing under oath, in accordance with Federal Rule of Civil Procedure 33. Each answer shall restate the interrogatory to which it responds immediately preceding the answer.

2. If Plaintiff objects to any interrogatory or any part thereof, Plaintiff shall state the objection with specificity, including the legal and factual bases for the objection, and shall answer the interrogatory to the extent it is not objectionable. A general or boilerplate objection, without more, shall not be deemed a proper objection. An objection to part of an interrogatory does not excuse Plaintiff from answering the remainder.

3. If Plaintiff lacks sufficient information to answer any interrogatory fully, Plaintiff shall so state, describe the efforts made to obtain the information, and answer to the fullest extent of Plaintiff's current knowledge, information, and belief. Plaintiff may not refuse to answer an interrogatory simply because the answer is not fully known; Plaintiff must answer to the extent the information is available.

4. All answers must be supplemented or corrected in a timely manner in accordance with Federal Rule of Civil Procedure 26(e). If Plaintiff learns that a prior answer is incomplete or incorrect in any material respect, Plaintiff is obligated to serve supplemental or corrected answers promptly.

5. These interrogatories are continuing in nature. Plaintiff is under a continuing obligation to supplement answers if additional, corrective, or different information becomes known or available to Plaintiff after the initial responses are served.

6. Where an interrogatory calls for information over a period of time or asks Plaintiff to break down information by calendar year or other time period, Plaintiff shall provide the information broken down by the time periods requested. If Plaintiff cannot reasonably provide a breakdown by the time periods requested, Plaintiff shall provide the information for the entire Relevant Period and explain why a breakdown by time period is not feasible.

7. These interrogatories are deemed to include all subparts thereof. The subparts within each interrogatory are logically related and are part of a single interrogatory. Collectively, these interrogatories (Nos. 1–25) do not exceed the twenty-five (25) interrogatory limit prescribed by Federal Rule of Civil Procedure 33(a)(1) and Local Rule 33.2 of the Northern District of Texas.

8. If Plaintiff elects to produce business records in lieu of an answer pursuant to Federal Rule of Civil Procedure 33(d), Plaintiff shall specify the records from which the answer may be derived or ascertained and shall identify such records with sufficient detail and specificity to enable Defendant to locate, identify, and ascertain the answer as readily as Plaintiff could. A general reference to voluminous records or a document production shall not constitute a sufficient specification under Rule 33(d).

INTERROGATORIES

INTERROGATORY NO. 1: Personal Background and Identification

State Your full legal name, including any aliases, prior names, maiden names, or other names by which You have been known at any time. In addition, state the following: (a) Your date of birth; (b) Your current residential address (known to Defendant to be 3417 Calmont Avenue, Fort Worth, TX 76107, per available records); (c) all residential addresses at which You have resided during the Relevant Period; (d) all telephone numbers (including cellular, home, and business) currently in Your possession or use; (e) all email addresses currently in Your possession or use, including any email addresses used during the Relevant Period; (f) the last four digits of Your Social Security Number; and (g) Your driver's license number and the state of issuance, including the current expiration date and the class of license held.

INTERROGATORY NO. 2: Work History with SLG — Overview

Describe in detail Your entire work history with Stonefield Logistics Group Inc., from the inception of Your relationship with SLG to its conclusion, including without limitation: (a) the date on which You first began performing Delivery Services for SLG (known to Defendant to be approximately March 2021, based on SLG's records); (b) the date on which You last performed Delivery Services for SLG (known to Defendant to be approximately September 2024, based on SLG's records); (c) each SLG distribution hub or facility at which You were assigned, reported, loaded, or from which You performed Delivery Services, including HUB-01 (Fort Worth) and any other hub(s), identifying each hub by name, location, and the period(s) during which You were assigned to or performed services from that hub; (d) the type(s) of Delivery Services You performed during Your tenure with SLG (e.g., standard last-mile residential delivery, white-glove delivery, regional freight delivery, or any other category of service), and describe the nature and frequency of each type; and (e) the circumstances and reasons for the termination or cessation of Your relationship with SLG, including whether the termination was initiated by You, by SLG, or by mutual agreement, and a detailed description of the events and Communications leading to the termination.

INTERROGATORY NO. 3: ICOA Execution History

Identify each version of the Independent Contractor Operating Agreement that You signed, executed, or otherwise agreed to with SLG, including: (a) the date(s) of execution of each ICOA; (b) the version number, revision date, or other identifying designation of each ICOA (including, without limitation, version 1.0 (originally promulgated 2018), version 2.0 (revised August 2020), and/or version 3.0 (revised January 2023)); (c) whether You read and understood the terms and conditions of each ICOA in their entirety prior to signing, and if You did not read or understand any portion, identify the specific provisions You did not read or did not understand; and (d) whether You consulted with, sought advice from, or discussed the terms of any ICOA with any attorney, financial advisor, tax professional, family member, friend, fellow driver, or other person prior to signing, and if so, identify each such person and describe the substance of each such consultation or discussion.

INTERROGATORY NO. 4: Understanding of Independent Contractor Status

Describe in detail Your understanding of Your classification as an independent contractor at the time You signed each version of the ICOA, including: (a) what You understood the term "independent contractor" to mean and how You understood that classification to differ from "employee" status; (b) whether any representative, employee, manager, recruiter, or agent of SLG explained the independent contractor classification to You at any time, and if so, identify each such SLG representative and describe in detail what was communicated, including the date, manner, and substance of each such Communication; (c) whether You were aware at the time of signing each ICOA that Your independent contractor classification would affect Your eligibility for benefits such as health insurance, retirement plans, workers' compensation, unemployment insurance, and overtime pay; and (d) the first date, if any, on which You began to believe that You were misclassified as an independent contractor rather than an employee, and describe in detail all facts, circumstances, events, Communications, and information giving rise to that belief.

INTERROGATORY NO. 5: Weekly Hours Worked

For each calendar year during the Relevant Period (i.e., 2022, 2023, 2024, and 2025 through the present), state the following: (a) Your average number of hours per week spent performing Delivery Services for SLG, including time spent driving, delivering packages or freight, obtaining signatures or delivery confirmations, and any time spent waiting at delivery locations; (b) Your average number of hours per week spent on activities related to SLG Delivery Services but not involving actual deliveries, including but not limited to vehicle loading and unloading at distribution hubs, route planning and preparation, vehicle maintenance and cleaning, fueling, attending training sessions, completing paperwork or digital logs, and communicating with SLG dispatchers or managers; (c) the maximum number of hours You worked in any single week and the minimum number of hours You worked in any single week, and for each, identify the approximate week and the circumstances giving rise to the maximum or minimum; and (d) the method(s) by which You tracked, recorded, or estimated Your hours, including any logs, timesheets, applications, calendars, GPS records, or other records maintained, whether in paper or electronic form, and identify the current location and custodian of any such records.

INTERROGATORY NO. 6: Daily and Weekly Schedule

Describe Your typical daily and weekly work schedule during the Relevant Period, including: (a) the days of the week on which You typically performed Delivery Services for SLG and the approximate number of days per week; (b) Your typical start time and end time on each delivery day, including any variation by day of the week; (c) the extent to which You had discretion to set Your own start and end times within SLG's required delivery windows, which Defendant understands to have been 7:00 AM through 8:00 PM, Monday through Saturday, and whether You ever performed deliveries outside of those delivery windows; (d) any days on which You were available to perform Delivery Services but declined to do so, the approximate frequency with which You declined available delivery days over the Relevant Period, and the reasons for each such declination; (e) whether You took any extended periods off (defined for purposes of this interrogatory as any period of more than one consecutive week during which You did not perform Delivery Services for SLG) during Your tenure with SLG, and if so, describe the approximate dates, duration, and circumstances of each such period, including whether You notified SLG in advance and whether SLG imposed any consequences as a result; and (f) whether You ever performed Delivery Services on a Sunday, a federal holiday, or outside of the standard delivery window, and if so, the approximate frequency and circumstances.

INTERROGATORY NO. 7: Compensation and Pay Records

For each calendar year during the Relevant Period (i.e., 2022, 2023, 2024, and 2025 through the present), state the following: (a) Your total gross compensation received from SLG, including all payments of any kind; (b) the total number of deliveries You completed for SLG; (c) the per-delivery rates applicable to Your deliveries, including the range of rates and any variations by delivery type, package weight, distance, geographic zone, or other factor (Defendant's records reflect a per-delivery rate range of $14.50 to $38.00, as set forth in the ICOA rate schedule); (d) whether You received any bonuses, incentive payments, fuel surcharges, peak-season supplements, referral bonuses, or other compensation from SLG beyond the standard per-delivery payments, and if so, describe the nature, amount, and frequency of each; (e) Your average weekly gross pay received from SLG (Defendant's records for calendar year 2023 reflect an average weekly gross payment to Plaintiff of approximately $1,247.00); and (f) whether You ever disputed, questioned, or raised a concern about any payment amount, rate, or calculation with SLG, and if so, describe the date, the nature of the dispute, the SLG representative(s) with whom You communicated, and the resolution or outcome of each such dispute.

INTERROGATORY NO. 8: Tax Filings and Schedule C

For each tax year covering any portion of the Relevant Period (i.e., tax years 2022, 2023, and 2024), state the following: (a) whether You filed a federal income tax return (Form 1040 or any variant thereof) for each such tax year; (b) whether You filed a Schedule C (Profit or Loss from Business) or Schedule C-EZ with respect to income earned from SLG for each such tax year; (c) the gross income reported on each Schedule C that is attributable to compensation received from SLG; (d) the total business expenses claimed on each Schedule C, and describe the principal categories of expenses claimed (e.g., vehicle expenses, fuel, insurance, depreciation, supplies, phone, and any other categories); (e) the net profit or loss reported on each Schedule C; (f) whether You received IRS Form 1099-NEC or Form 1099-MISC from SLG for each such tax year, and the amount reported on each such form; (g) the name, address, and telephone number of any tax preparer, accountant, enrolled agent, or other professional who assisted You in the preparation of Your tax returns for each such year; and (h) whether You claimed any other self-employment income from any other source on any Schedule C or other tax form for each such tax year, and if so, identify the source and the amount.

INTERROGATORY NO. 9: Vehicle Ownership and Expenses

Describe each vehicle You used to perform Delivery Services for SLG during the Relevant Period, including: (a) the make, model, year, color, and Vehicle Identification Number (VIN) of each vehicle; (b) whether You owned, leased, or financed each vehicle, and if leased or financed, identify the leasing company or lender, the monthly payment amount, the term of the lease or loan, and the total amount paid during the Relevant Period; (c) whether each vehicle met SLG's vehicle specifications as set forth in the ICOA (which Defendant understands to require a cargo van or box truck with a model year of 2015 or newer, meeting specified cargo capacity requirements); (d) whether each vehicle passed SLG's vehicle safety inspection(s), the date(s) of each inspection, the location of each inspection, and the identity of the SLG representative or inspector who conducted each inspection; (e) all vehicle-related expenses You incurred in connection with the performance of Delivery Services for SLG during the Relevant Period, including but not limited to fuel and gasoline, vehicle insurance premiums, maintenance and routine service, repairs, tires, registration and license fees, tolls, parking, vehicle washes, depreciation, and any other vehicle-related costs, broken down by calendar year and by category of expense; and (f) the total amount of all such vehicle expenses for each calendar year during the Relevant Period, and the method by which You tracked, recorded, or calculated such expenses.

INTERROGATORY NO. 10: Vehicle Insurance

State whether You maintained Your own vehicle insurance at all times during the Relevant Period, and if so, provide the following information for each insurance policy in effect during the Relevant Period: (a) the name and address of the insurance carrier or company; (b) the policy number, the effective dates and expiration dates of each policy period, and the coverage limits for liability, collision, comprehensive, and any other applicable coverage; (c) whether the policy provided commercial vehicle insurance coverage, personal automobile insurance coverage, or a combination thereof, and whether the policy specifically covered the use of Your vehicle for delivery or courier services; and (d) the annual or semi-annual premium paid for each policy, broken down by policy period. If Your vehicle insurance lapsed, was canceled, or was not in effect at any time during the Relevant Period, describe the dates during which coverage was not in effect, the reason for the lapse or cancellation, and whether You performed Delivery Services for SLG during any period in which You did not have valid vehicle insurance coverage.

INTERROGATORY NO. 11: Earnings from Other Delivery Platforms or Sources

Identify each Delivery Platform, courier service, logistics company, or other entity for which You performed Delivery Services or any other transportation, courier, or logistics work during the Relevant Period, other than Stonefield Logistics Group Inc., including: (a) the full name and address of each such entity or platform; (b) the dates during which You performed services for each, including the start date and end date (or indicate if ongoing); (c) the type of services performed for each entity or platform; (d) the total compensation received from each entity or platform, broken down by calendar year; (e) whether You were classified as an independent contractor or an employee by each such entity or platform, and whether You signed any independent contractor agreement or employment agreement with each; and (f) whether any such engagement overlapped in time with Your services for SLG—that is, whether You performed services for any other entity or platform during any period in which You were also performing Delivery Services for SLG—and if so, describe the extent of the overlap and whether You performed services for SLG and the other entity on the same day or during the same week.

INTERROGATORY NO. 12: Other Employment and Income Sources

For the Relevant Period, identify all sources of income, earnings, compensation, or benefits received by You other than SLG and any Delivery Platforms identified in Your response to Interrogatory No. 11, including: (a) any employment, whether part-time or full-time, with any employer, and for each, state the name and address of the employer, the dates of employment, Your job title or position, and the total compensation received, broken down by calendar year; (b) any self-employment, freelance work, gig work, or independent business activity of any kind, and for each, describe the nature of the work, the dates, and the total compensation or revenue received, broken down by calendar year; (c) any unemployment insurance benefits received from any state agency, including the dates received and the total amount; (d) any government assistance or benefits received, including Social Security benefits, disability benefits, food assistance, housing assistance, or any other form of public assistance; and (e) for each source identified, state the name of the employer, payor, or source, the dates of employment, engagement, or receipt, and the total compensation or benefits received during the Relevant Period.

INTERROGATORY NO. 13: Subcontracting Efforts

Describe each instance during the Relevant Period in which You sought to Subcontract, delegate, or assign any portion of the Delivery Services that You were engaged to perform for SLG to another person, including: (a) the date(s) of each such request or effort to Subcontract; (b) the SLG representative, manager, or dispatcher to whom each request was made, and the manner in which the request was communicated (e.g., in person, by telephone, by email, through RouteSync); (c) whether SLG's approval was granted or denied for each request; (d) if approved, identify the subcontractor by name, address, and telephone number, describe the dates and scope of the subcontracted services, and describe the compensation arrangement between You and the subcontractor, including the amount paid to the subcontractor for each subcontracted assignment; (e) if denied, describe the reason(s) given by SLG for the denial, the identity of the SLG representative who communicated the denial, and any follow-up Communications regarding the denial; and (f) if You never sought to Subcontract any portion of Your Delivery Services during the Relevant Period, state so explicitly and explain the reasons why You did not, including whether You believed You were permitted to do so under the ICOA and whether any SLG representative communicated any policy or position regarding Subcontracting.

INTERROGATORY NO. 14: RouteSync and Delivery Acceptance

Describe in detail Your use of SLG's RouteSync dispatch platform during the Relevant Period, including: (a) whether You had the ability to accept or decline individual delivery assignments offered to You through RouteSync, and if so, describe the process by which assignments were offered, accepted, or declined; (b) the approximate frequency with which You declined delivery assignments that were offered to You through RouteSync, expressed as a percentage of total offers received or as a number of declined assignments per week or per month; (c) Your approximate delivery acceptance rate over the Relevant Period (that is, the percentage of delivery assignments offered to You that You accepted), and how that rate compares to the 85% minimum acceptance rate referenced in the ICOA; (d) whether You were ever notified by SLG that Your acceptance rate had fallen below 85% or below any other threshold, and if so, describe each such notification, including the date, the method of notification, the SLG representative involved, the specific acceptance rate cited, and any consequences imposed or threatened, including any "performance review" or other process described in the ICOA; (e) if You were subject to a performance review or any other process as a result of a low acceptance rate, describe the process, the participants, the outcome, and any changes to Your delivery assignments or status that resulted; and (f) the extent to which RouteSync dictated, assigned, or suggested Your delivery route, sequence, or order of deliveries on any given day, versus the extent to which You were permitted to exercise Your own discretion in selecting and ordering Your delivery route, and describe any instances in which RouteSync's suggested route conflicted with Your preferred route and how You resolved such conflicts.

INTERROGATORY NO. 15: Route Discretion and Deviations

Describe the extent of discretion You exercised regarding delivery routes during the Relevant Period, including: (a) whether You followed the routes assigned, suggested, or generated by RouteSync, or whether You regularly selected Your own routes independent of RouteSync's suggestions; (b) the approximate frequency with which You deviated from RouteSync-suggested routes, expressed as a percentage of delivery days or total deliveries; (c) the reasons for any deviations from RouteSync-suggested routes, including but not limited to traffic conditions, road closures, personal preference, efficiency, customer requests, or any other reason; and (d) whether SLG ever disciplined You, counseled You, issued a warning to You, reduced Your delivery assignments, or took any other adverse action against You as a result of route deviations, and if so, describe each such instance in detail, including the date, the SLG representative involved, the nature of the adverse action, and the outcome.

INTERROGATORY NO. 16: Uniforms, Branding, and Equipment

Describe all uniforms, branded apparel, vehicle placards, vehicle magnets, decals, identification badges, handheld scanners, telematics devices, and any other equipment, supplies, or materials that SLG required You to use, wear, display, or maintain during the Relevant Period, including: (a) each specific item that was required; (b) whether SLG provided each item to You at no cost, at a subsidized cost, or whether You were required to purchase, rent, or otherwise obtain each item at Your own expense; (c) for any item You purchased or paid for, the cost of each item and the date of purchase; (d) whether You ever performed Delivery Services without wearing the required uniform, displaying the required SLG branding on Your vehicle, or using the required equipment, and if so, describe the circumstances of each such occasion, the approximate frequency, and any SLG response, discipline, or consequence that resulted; and (e) whether You were required to return any SLG-provided equipment or materials upon the termination of Your relationship with SLG, and if so, whether You returned such items and the date of return.

INTERROGATORY NO. 17: Training

Describe all training required or provided by SLG during the Relevant Period and throughout Your tenure with SLG, including: (a) the initial onboarding or orientation training program, including its total duration (understood by Defendant to be approximately 16 hours), the dates on which You completed the initial training, the location at which training was conducted, and the format (e.g., in-person, online, or a combination); (b) all quarterly or periodic training sessions required by SLG, including the approximate duration of each session (understood by Defendant to be approximately 4 hours per session), the dates on which You attended each session, and the location and format of each session; (c) the specific topics covered in each training session, including but not limited to safety protocols, customer service standards, delivery procedures, RouteSync operation, package handling, vehicle inspection, compliance with regulations, and any other subject matter; (d) whether attendance at each training session was mandatory or voluntary, and if mandatory, the consequences for failure to attend; (e) whether You were compensated for the time spent attending training sessions, and if so, the rate and amount of compensation received for training time, and if not, whether You believe You should have been compensated; and (f) the consequences, if any, imposed or threatened by SLG for failing to attend a required training session, including any warnings, suspension of delivery assignments, performance reviews, or termination.

INTERROGATORY NO. 18: GPS Tracking and Monitoring

Describe Your knowledge and experience with SLG's GPS telematics tracking and monitoring practices during the Relevant Period, including: (a) whether an SLG-provided or SLG-required telematics device was installed on Your vehicle(s), and if so, the type or brand of device and whether the device was installed by SLG personnel or by You; (b) the approximate date(s) on which the telematics device was first installed on each of Your vehicles; (c) whether You understood, at the time of installation and throughout the Relevant Period, that SLG monitored Your location, speed, driving behavior, stops, idle time, and route adherence through data transmitted by the telematics device; (d) whether You were ever contacted, counseled, warned, or disciplined by SLG based on data collected from the telematics device, and if so, describe each such instance in detail, including the date, the SLG representative involved, the specific data or behavior referenced, and any consequences or actions taken; and (e) whether You ever disabled, tampered with, disconnected, removed, or otherwise interfered with the operation of the telematics device, and if so, describe the circumstances, the date(s), the reason(s), and SLG's response.

INTERROGATORY NO. 19: Performance Reviews and Discipline

Describe each instance during the Relevant Period in which SLG took any of the following actions with respect to You: (a) conducted a formal or informal performance review, evaluation, or assessment of Your Delivery Services; (b) issued any warning, written or verbal counseling, corrective action notice, or similar communication regarding Your performance; (c) reduced the number or frequency of delivery assignments offered to You; (d) suspended Your ability to receive or accept delivery assignments through RouteSync or otherwise; or (e) took any other adverse action against You, including but not limited to fines, penalties, reassignment to a different hub, modification of Your per-delivery rate, or termination or threatened termination of the ICOA. For each such instance, state the date, identify the SLG representative(s) involved, describe the reason(s) given for the action, describe the substance of any Communications relating to the action, and describe the outcome or resolution, including any changes to Your delivery assignments, compensation, or status that resulted.

INTERROGATORY NO. 20: Non-Compete Provision

Describe Your understanding of the non-compete clause contained in the ICOA (which provides for a 12-month restriction within a 50-mile radius of the assigned distribution hub), including: (a) whether You were aware of the non-compete provision at the time You signed each version of the ICOA, and if so, describe Your understanding of the provision's scope, duration, and geographic limitation; (b) whether the non-compete provision affected, restricted, or deterred Your ability to perform delivery, logistics, courier, or transportation work for other entities during Your tenure with SLG, and if so, describe how and to what extent; (c) whether You performed delivery, logistics, courier, or transportation work for any entity that could be considered a competitor of SLG within a 50-mile radius of Your assigned distribution hub at any time during Your tenure with SLG or during the 12-month period following Your separation from SLG, and if so, identify each such entity and describe the nature and duration of the work performed; and (d) whether SLG ever sought to enforce, threaten to enforce, or communicate any intent to enforce the non-compete provision against You, and if so, describe each such instance, including the date, the SLG representative involved, the substance of the Communication, and the outcome.

INTERROGATORY NO. 21: Communications with Other SLG Drivers Regarding This Litigation

Identify each Communication You have had with any current or former SLG driver, service provider, or independent contractor regarding this lawsuit, the claims asserted herein, the possibility of filing a consent form to join this action as an opt-in plaintiff, or any facts relating to the allegations in this action, including: (a) the full name, last known address, telephone number, and email address of each such driver or person; (b) the date(s) of each Communication; (c) the method or medium of each Communication (e.g., in person, telephone, text message, email, social media platform, messaging application, or other means); (d) the substance and content of each Communication, described in sufficient detail to convey the information exchanged; and (e) whether each such Communication was initiated by You, by the other driver or person, by Your counsel at Hartwell & Brashear PLLC, or by any other person acting on Your behalf or at Your direction.

INTERROGATORY NO. 22: Communications with Plaintiff's Counsel

State the following with respect to Your engagement of legal counsel in connection with this action: (a) the date on which You first communicated with Hartwell & Brashear PLLC or any other attorney, law firm, legal aid organization, or legal services provider regarding potential claims against SLG, including wage-and-hour claims, misclassification claims, or any other claims; (b) the manner in which You became aware of Hartwell & Brashear PLLC, including whether You learned of the firm through an advertisement, a website, social media, a referral from another person, or any other means; (c) whether You were referred to Hartwell & Brashear PLLC by another person, and if so, identify that person by name, address, and telephone number, and describe the circumstances of the referral; (d) whether You have a written engagement agreement, retainer agreement, or representation agreement with Hartwell & Brashear PLLC, and if so, the date of execution of such agreement; and (e) the fee arrangement between You and Your counsel, including whether the engagement is on a contingency fee basis, and if so, the contingency fee percentage or structure, and whether You are responsible for any costs or expenses regardless of the outcome of this action.

INTERROGATORY NO. 23: Declarations and Opt-In Solicitation

Describe in detail any and all efforts that You or Your counsel at Hartwell & Brashear PLLC have undertaken to solicit, recruit, or encourage current or former SLG drivers to file opt-in consent forms to join this action as plaintiffs, including: (a) the methods of solicitation employed, including but not limited to social media postings or advertisements, direct personal contact, telephone calls, text messages, emails, mailers, flyers, online advertisements, attorney websites, or any other method; (b) the dates of each solicitation effort or campaign; (c) the total number of current or former SLG drivers contacted, directly or indirectly, in connection with solicitation efforts; (d) the total number of opt-in consent forms received to date; (e) the identity of each person who has signed an opt-in consent form, including full name, last known address, telephone number, and the date the consent form was signed; and (f) a description of any declarations, affidavits, or sworn statements obtained from current or former SLG drivers that have been or will be submitted in support of Plaintiff's Motion for Conditional Certification (filed July 14, 2025), including the identity of each declarant or affiant, the date of each declaration or affidavit, and a summary of the subject matter addressed therein.

INTERROGATORY NO. 24: Prior Litigation and Claims

State whether You have ever been involved in any of the following, at any time in Your life, whether as a party, a putative class member, or a witness: (a) a plaintiff, named plaintiff, class representative, lead plaintiff, or opt-in plaintiff in any lawsuit, class action, collective action, arbitration, mediation, administrative proceeding, or other legal claim or proceeding of any kind, including but not limited to wage-and-hour claims, employment discrimination claims, wrongful termination claims, personal injury claims, breach of contract claims, consumer protection claims, or any other type of claim; (b) a respondent, defendant, or adverse party in any such proceeding; or (c) the filing of a complaint, charge, claim, or petition with any federal, state, or local agency, including but not limited to the United States Department of Labor, the Equal Employment Opportunity Commission, the Texas Workforce Commission, any state department of labor, any workers' compensation board, or any other governmental agency. For each such matter, state the case caption or title, the case number or docket number, the name and location of the court or agency, the date filed or initiated, the nature of the claims asserted, the identity of all parties, the current status, and the outcome or resolution (including any settlement, judgment, dismissal, or withdrawal).

INTERROGATORY NO. 25: Damages Calculation

Describe in detail the factual and computational basis for all damages You seek in this action, both individually and on behalf of the putative collective, including: (a) the total amount of unpaid overtime compensation You allege is owed to You individually; (b) the specific time period and the total number of weeks for which You seek unpaid overtime compensation; (c) the regular rate of pay You contend should apply for purposes of calculating overtime, and the factual and legal basis for that rate (Defendant understands Plaintiff has alleged an effective hourly rate of approximately $21.50, derived by dividing average weekly pay of $1,247.00 by 58 hours per week); (d) the overtime rate You contend applies and the basis for that rate (Defendant understands Plaintiff has alleged an overtime rate of $32.25 per hour, calculated as 1.5 times the alleged regular rate of $21.50); (e) the average number of overtime hours per week You claim to have worked in excess of 40 hours (Defendant understands Plaintiff has alleged approximately 18 overtime hours per week, based on a claim of approximately 58 hours worked per week); (f) the specific calculation method used to arrive at Your individual damages figure, set forth in a step-by-step computation showing each variable and the mathematical operations applied; (g) any other categories of damages You seek in this action, including but not limited to liquidated damages under 29 U.S.C. § 216(b), statutory penalties, pre-judgment interest, post-judgment interest, attorneys' fees, costs, and any other relief; and (h) identify each Document, record, data source, expert report, or other material upon which You rely or intend to rely in computing or supporting Your damages, and for each, state whether it is currently in Your possession, custody, or control, or in the possession, custody, or control of a third party, and if a third party, identify that party.

Defendant Stonefield Logistics Group Inc. respectfully requests that Plaintiff Marcus Delano answer each of the foregoing interrogatories separately, fully, and under oath, within thirty (30) days of service, in accordance with Federal Rule of Civil Procedure 33. Defendant reserves the right to propound additional interrogatories as permitted by the Federal Rules of Civil Procedure, the Local Rules of the Northern District of Texas, and any orders of this Court.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Bernard Crawford State Bar No. 24078631 Responsible Partner

James Underwood State Bar No. 24112459 Lead Associate

Devon Archer State Bar No. 24126803 Working Associate

CALDERWOOD & HARKNESS LLP 2200 Ross Avenue, Suite 3600 Dallas, TX 75201 Telephone: (214) 756-4200 Facsimile: (214) 756-4201

Email: bcrawford@calderwoodharkness.com

Email: junderwood@calderwoodharkness.com

Email: darcher@calderwoodharkness.com

ATTORNEYS FOR DEFENDANT STONEFIELD LOGISTICS GROUP INC.

CERTIFICATE OF SERVICE

I hereby certify that on June 23, 2025, a true and correct copy of Defendant Stonefield Logistics Group Inc.'s First Set of Interrogatories to Plaintiff Marcus Delano (Interrogatory Nos. 1–25) was served upon all counsel of record via the Court's CM/ECF electronic filing system, which constitutes service upon the following:

Claudia Hartwell Jordan Brashear Hartwell & Brashear PLLC 500 N. Akard Street, Suite 1750 Dallas, TX 75201 Telephone: (214) 932-8100 Facsimile: (214) 932-8101

Email: chartwell@hartwellbrashear.com

Email: jbrashear@hartwellbrashear.com

Lead Counsel for Plaintiff Marcus Delano

________________________________________

Devon Archer

MARCUS DELANO, individually and on behalf of all others similarly situated,

Plaintiff,

Civil Action No. 3:25-cv-01847-RBC

Hon. Rebecca Chen

STONEFIELD LOGISTICS GROUP INC.,	U.S. District Judge
<!-- indent:1 -->Defendant.<!-- /indent -->	Hon. Timothy Farrell

U.S. Magistrate Judge

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION
DEFENDANT STONEFIELD LOGISTICS GROUP INC.'S FIRST SET OF INTERROGATORIES TO PLAINTIFF MARCUS DELANO (Interrogatory Nos. 1–25)
June 23, 2025
Defendant Stonefield Logistics Group Inc. ("Stonefield" or "SLG"), by and through its counsel of record, Calderwood & Harkness LLP, hereby propounds the following First Set of Interrogatories (Nos. 1–25) upon Plaintiff Marcus Delano ("Plaintiff"), pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure. Plaintiff is required to answer each interrogatory separately, fully, and under oath, within thirty (30) days of service of these interrogatories. All answers must be made in compliance with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the Northern District of Texas, and any applicable orders of the Court.
These interrogatories are propounded by and through the following counsel:
Bernard Crawford, Responsible Partner James Underwood, Lead Associate Devon Archer, Working Associate
Calderwood & Harkness LLP 2200 Ross Avenue, Suite 3600 Dallas, TX 75201
DEFINITIONS
As used in these interrogatories, the following terms shall have the meanings set forth below. These definitions are intended to supplement, not limit, the ordinary meaning of any term, and they shall apply regardless of whether a term is capitalized.
1. "You," "Your," or "Plaintiff" shall mean Marcus Delano, individually, including his agents, representatives, attorneys, accountants, tax preparers, and any other person acting or purporting to act on his behalf or at his direction.
2. "SLG," "Stonefield," or "Defendant" shall mean Stonefield Logistics Group Inc., including its current and former officers, directors, employees, agents, subsidiaries, affiliates, predecessors, successors, assigns, and any other person acting or purporting to act on its behalf.
3. "ICOA" shall mean the Independent Contractor Operating Agreement between Plaintiff and SLG, including all versions thereof: version 1.0 (originally promulgated in 2018), version 2.0 (revised August 2020), and version 3.0 (revised January 2023), together with any and all amendments, addenda, supplements, exhibits, schedules, appendices, side letters, or other modifications thereto, whether written or oral.
4. "Relevant Period" shall mean the period from April 30, 2022 through the present date, inclusive. This period corresponds to the applicable limitations period as pleaded in Plaintiff's Complaint.
5. "Delivery Services" shall mean any and all last-mile delivery, regional freight delivery, white-glove delivery, or other transportation, courier, or logistics services performed by or on behalf of Plaintiff, whether for SLG or any other entity.
6. "RouteSync" shall mean SLG's proprietary dispatch, routing, and delivery management software platform, including the mobile application and any web-based portal or dashboard associated therewith.
7. "Document" or "Documents" shall have the broadest meaning permitted under Federal Rule of Civil Procedure 34(a) and shall include, without limitation, all writings, drawings, graphs, charts, photographs, sound recordings, images, and other data or data compilations—stored in any medium from which information can be obtained—including all electronically stored information ("ESI"), whether in native format or otherwise, and including metadata associated therewith.
8. "Communication" or "Communications" shall mean any oral, written, or electronic exchange, transmission, or receipt of information between two or more persons, by any means, including but not limited to letters, memoranda, emails, text messages (including SMS and MMS), instant messages (including messages sent via Meridian Services Inc., Signal, Kestrel Data Systems, Dunmore Software, or any similar application), social media posts, comments, or direct messages, telephone calls, voicemails, video calls, video conferences, and in-person conversations.
9. "Person" shall mean any natural person, corporation, partnership, limited liability company, joint venture, association, trust, estate, governmental entity or agency, or any other legal entity or organization, whether or not a party to this action.
10. "Identify" (when used with respect to a Person) shall mean to state the person's full legal name, last known residential or business address, last known telephone number(s), last known email address(es), current or most recent employer, and job title, position, or relationship to any party to this action.
11. "Identify" (when used with respect to a Document) shall mean to state the type or nature of the Document, the date of the Document, the author(s) or creator(s), the recipient(s) or addressee(s), the subject matter or general content, and the current custodian or location of the Document (or, if the Document is no longer in existence, the date and circumstances of its destruction or loss).
12. "Delivery Platform" shall mean any company, application, digital platform, or service through which Plaintiff performed or could have performed delivery, courier, transportation, or logistics services, other than Stonefield Logistics Group Inc. This term includes, without limitation, platforms such as Ashbury Corporation, Aldermere Enterprises, Fenmore Holdings, Fenmore Group, Cobalt Ridge Corporation, Dunmore Corporation, Strathmore Holdings, Halcyon Partners LLC, and any similar service or entity.
13. "Subcontract" or "Subcontracting" shall mean any arrangement, whether formal or informal, written or oral, by which Plaintiff delegated, assigned, hired, or engaged another person to perform all or any portion of the Delivery Services that Plaintiff was engaged to perform for SLG under the ICOA.
14. "Opt-In Driver" or "Putative Collective Member" shall mean any current or former SLG driver or service provider who has filed or indicated an intent to file a written consent form to join this action pursuant to 29 U.S.C. § 216(b), or any driver or service provider with whom Plaintiff or Plaintiff's counsel has communicated regarding this action, the claims asserted herein, or the possibility of joining this action.
INSTRUCTIONS
The following instructions apply to each interrogatory set forth below and shall be read in conjunction with the Definitions set forth above.
1. Each interrogatory shall be answered separately and fully in writing under oath, in accordance with Federal Rule of Civil Procedure 33. Each answer shall restate the interrogatory to which it responds immediately preceding the answer.
2. If Plaintiff objects to any interrogatory or any part thereof, Plaintiff shall state the objection with specificity, including the legal and factual bases for the objection, and shall answer the interrogatory to the extent it is not objectionable. A general or boilerplate objection, without more, shall not be deemed a proper objection. An objection to part of an interrogatory does not excuse Plaintiff from answering the remainder.
3. If Plaintiff lacks sufficient information to answer any interrogatory fully, Plaintiff shall so state, describe the efforts made to obtain the information, and answer to the fullest extent of Plaintiff's current knowledge, information, and belief. Plaintiff may not refuse to answer an interrogatory simply because the answer is not fully known; Plaintiff must answer to the extent the information is available.
4. All answers must be supplemented or corrected in a timely manner in accordance with Federal Rule of Civil Procedure 26(e). If Plaintiff learns that a prior answer is incomplete or incorrect in any material respect, Plaintiff is obligated to serve supplemental or corrected answers promptly.
5. These interrogatories are continuing in nature. Plaintiff is under a continuing obligation to supplement answers if additional, corrective, or different information becomes known or available to Plaintiff after the initial responses are served.
6. Where an interrogatory calls for information over a period of time or asks Plaintiff to break down information by calendar year or other time period, Plaintiff shall provide the information broken down by the time periods requested. If Plaintiff cannot reasonably provide a breakdown by the time periods requested, Plaintiff shall provide the information for the entire Relevant Period and explain why a breakdown by time period is not feasible.
7. These interrogatories are deemed to include all subparts thereof. The subparts within each interrogatory are logically related and are part of a single interrogatory. Collectively, these interrogatories (Nos. 1–25) do not exceed the twenty-five (25) interrogatory limit prescribed by Federal Rule of Civil Procedure 33(a)(1) and Local Rule 33.2 of the Northern District of Texas.
8. If Plaintiff elects to produce business records in lieu of an answer pursuant to Federal Rule of Civil Procedure 33(d), Plaintiff shall specify the records from which the answer may be derived or ascertained and shall identify such records with sufficient detail and specificity to enable Defendant to locate, identify, and ascertain the answer as readily as Plaintiff could. A general reference to voluminous records or a document production shall not constitute a sufficient specification under Rule 33(d).
INTERROGATORIES
INTERROGATORY NO. 1: Personal Background and Identification
State Your full legal name, including any aliases, prior names, maiden names, or other names by which You have been known at any time. In addition, state the following: (a) Your date of birth; (b) Your current residential address (known to Defendant to be 3417 Calmont Avenue, Fort Worth, TX 76107, per available records); (c) all residential addresses at which You have resided during the Relevant Period; (d) all telephone numbers (including cellular, home, and business) currently in Your possession or use; (e) all email addresses currently in Your possession or use, including any email addresses used during the Relevant Period; (f) the last four digits of Your Social Security Number; and (g) Your driver's license number and the state of issuance, including the current expiration date and the class of license held.
INTERROGATORY NO. 2: Work History with SLG — Overview
Describe in detail Your entire work history with Stonefield Logistics Group Inc., from the inception of Your relationship with SLG to its conclusion, including without limitation: (a) the date on which You first began performing Delivery Services for SLG (known to Defendant to be approximately March 2021, based on SLG's records); (b) the date on which You last performed Delivery Services for SLG (known to Defendant to be approximately September 2024, based on SLG's records); (c) each SLG distribution hub or facility at which You were assigned, reported, loaded, or from which You performed Delivery Services, including HUB-01 (Fort Worth) and any other hub(s), identifying each hub by name, location, and the period(s) during which You were assigned to or performed services from that hub; (d) the type(s) of Delivery Services You performed during Your tenure with SLG (e.g., standard last-mile residential delivery, white-glove delivery, regional freight delivery, or any other category of service), and describe the nature and frequency of each type; and (e) the circumstances and reasons for the termination or cessation of Your relationship with SLG, including whether the termination was initiated by You, by SLG, or by mutual agreement, and a detailed description of the events and Communications leading to the termination.
INTERROGATORY NO. 3: ICOA Execution History
Identify each version of the Independent Contractor Operating Agreement that You signed, executed, or otherwise agreed to with SLG, including: (a) the date(s) of execution of each ICOA; (b) the version number, revision date, or other identifying designation of each ICOA (including, without limitation, version 1.0 (originally promulgated 2018), version 2.0 (revised August 2020), and/or version 3.0 (revised January 2023)); (c) whether You read and understood the terms and conditions of each ICOA in their entirety prior to signing, and if You did not read or understand any portion, identify the specific provisions You did not read or did not understand; and (d) whether You consulted with, sought advice from, or discussed the terms of any ICOA with any attorney, financial advisor, tax professional, family member, friend, fellow driver, or other person prior to signing, and if so, identify each such person and describe the substance of each such consultation or discussion.
INTERROGATORY NO. 4: Understanding of Independent Contractor Status
Describe in detail Your understanding of Your classification as an independent contractor at the time You signed each version of the ICOA, including: (a) what You understood the term "independent contractor" to mean and how You understood that classification to differ from "employee" status; (b) whether any representative, employee, manager, recruiter, or agent of SLG explained the independent contractor classification to You at any time, and if so, identify each such SLG representative and describe in detail what was communicated, including the date, manner, and substance of each such Communication; (c) whether You were aware at the time of signing each ICOA that Your independent contractor classification would affect Your eligibility for benefits such as health insurance, retirement plans, workers' compensation, unemployment insurance, and overtime pay; and (d) the first date, if any, on which You began to believe that You were misclassified as an independent contractor rather than an employee, and describe in detail all facts, circumstances, events, Communications, and information giving rise to that belief.
INTERROGATORY NO. 5: Weekly Hours Worked
For each calendar year during the Relevant Period (i.e., 2022, 2023, 2024, and 2025 through the present), state the following: (a) Your average number of hours per week spent performing Delivery Services for SLG, including time spent driving, delivering packages or freight, obtaining signatures or delivery confirmations, and any time spent waiting at delivery locations; (b) Your average number of hours per week spent on activities related to SLG Delivery Services but not involving actual deliveries, including but not limited to vehicle loading and unloading at distribution hubs, route planning and preparation, vehicle maintenance and cleaning, fueling, attending training sessions, completing paperwork or digital logs, and communicating with SLG dispatchers or managers; (c) the maximum number of hours You worked in any single week and the minimum number of hours You worked in any single week, and for each, identify the approximate week and the circumstances giving rise to the maximum or minimum; and (d) the method(s) by which You tracked, recorded, or estimated Your hours, including any logs, timesheets, applications, calendars, GPS records, or other records maintained, whether in paper or electronic form, and identify the current location and custodian of any such records.
INTERROGATORY NO. 6: Daily and Weekly Schedule
Describe Your typical daily and weekly work schedule during the Relevant Period, including: (a) the days of the week on which You typically performed Delivery Services for SLG and the approximate number of days per week; (b) Your typical start time and end time on each delivery day, including any variation by day of the week; (c) the extent to which You had discretion to set Your own start and end times within SLG's required delivery windows, which Defendant understands to have been 7:00 AM through 8:00 PM, Monday through Saturday, and whether You ever performed deliveries outside of those delivery windows; (d) any days on which You were available to perform Delivery Services but declined to do so, the approximate frequency with which You declined available delivery days over the Relevant Period, and the reasons for each such declination; (e) whether You took any extended periods off (defined for purposes of this interrogatory as any period of more than one consecutive week during which You did not perform Delivery Services for SLG) during Your tenure with SLG, and if so, describe the approximate dates, duration, and circumstances of each such period, including whether You notified SLG in advance and whether SLG imposed any consequences as a result; and (f) whether You ever performed Delivery Services on a Sunday, a federal holiday, or outside of the standard delivery window, and if so, the approximate frequency and circumstances.
INTERROGATORY NO. 7: Compensation and Pay Records
For each calendar year during the Relevant Period (i.e., 2022, 2023, 2024, and 2025 through the present), state the following: (a) Your total gross compensation received from SLG, including all payments of any kind; (b) the total number of deliveries You completed for SLG; (c) the per-delivery rates applicable to Your deliveries, including the range of rates and any variations by delivery type, package weight, distance, geographic zone, or other factor (Defendant's records reflect a per-delivery rate range of $14.50 to $38.00, as set forth in the ICOA rate schedule); (d) whether You received any bonuses, incentive payments, fuel surcharges, peak-season supplements, referral bonuses, or other compensation from SLG beyond the standard per-delivery payments, and if so, describe the nature, amount, and frequency of each; (e) Your average weekly gross pay received from SLG (Defendant's records for calendar year 2023 reflect an average weekly gross payment to Plaintiff of approximately $1,247.00); and (f) whether You ever disputed, questioned, or raised a concern about any payment amount, rate, or calculation with SLG, and if so, describe the date, the nature of the dispute, the SLG representative(s) with whom You communicated, and the resolution or outcome of each such dispute.
INTERROGATORY NO. 8: Tax Filings and Schedule C
For each tax year covering any portion of the Relevant Period (i.e., tax years 2022, 2023, and 2024), state the following: (a) whether You filed a federal income tax return (Form 1040 or any variant thereof) for each such tax year; (b) whether You filed a Schedule C (Profit or Loss from Business) or Schedule C-EZ with respect to income earned from SLG for each such tax year; (c) the gross income reported on each Schedule C that is attributable to compensation received from SLG; (d) the total business expenses claimed on each Schedule C, and describe the principal categories of expenses claimed (e.g., vehicle expenses, fuel, insurance, depreciation, supplies, phone, and any other categories); (e) the net profit or loss reported on each Schedule C; (f) whether You received IRS Form 1099-NEC or Form 1099-MISC from SLG for each such tax year, and the amount reported on each such form; (g) the name, address, and telephone number of any tax preparer, accountant, enrolled agent, or other professional who assisted You in the preparation of Your tax returns for each such year; and (h) whether You claimed any other self-employment income from any other source on any Schedule C or other tax form for each such tax year, and if so, identify the source and the amount.
INTERROGATORY NO. 9: Vehicle Ownership and Expenses
Describe each vehicle You used to perform Delivery Services for SLG during the Relevant Period, including: (a) the make, model, year, color, and Vehicle Identification Number (VIN) of each vehicle; (b) whether You owned, leased, or financed each vehicle, and if leased or financed, identify the leasing company or lender, the monthly payment amount, the term of the lease or loan, and the total amount paid during the Relevant Period; (c) whether each vehicle met SLG's vehicle specifications as set forth in the ICOA (which Defendant understands to require a cargo van or box truck with a model year of 2015 or newer, meeting specified cargo capacity requirements); (d) whether each vehicle passed SLG's vehicle safety inspection(s), the date(s) of each inspection, the location of each inspection, and the identity of the SLG representative or inspector who conducted each inspection; (e) all vehicle-related expenses You incurred in connection with the performance of Delivery Services for SLG during the Relevant Period, including but not limited to fuel and gasoline, vehicle insurance premiums, maintenance and routine service, repairs, tires, registration and license fees, tolls, parking, vehicle washes, depreciation, and any other vehicle-related costs, broken down by calendar year and by category of expense; and (f) the total amount of all such vehicle expenses for each calendar year during the Relevant Period, and the method by which You tracked, recorded, or calculated such expenses.
INTERROGATORY NO. 10: Vehicle Insurance
State whether You maintained Your own vehicle insurance at all times during the Relevant Period, and if so, provide the following information for each insurance policy in effect during the Relevant Period: (a) the name and address of the insurance carrier or company; (b) the policy number, the effective dates and expiration dates of each policy period, and the coverage limits for liability, collision, comprehensive, and any other applicable coverage; (c) whether the policy provided commercial vehicle insurance coverage, personal automobile insurance coverage, or a combination thereof, and whether the policy specifically covered the use of Your vehicle for delivery or courier services; and (d) the annual or semi-annual premium paid for each policy, broken down by policy period. If Your vehicle insurance lapsed, was canceled, or was not in effect at any time during the Relevant Period, describe the dates during which coverage was not in effect, the reason for the lapse or cancellation, and whether You performed Delivery Services for SLG during any period in which You did not have valid vehicle insurance coverage.
INTERROGATORY NO. 11: Earnings from Other Delivery Platforms or Sources
Identify each Delivery Platform, courier service, logistics company, or other entity for which You performed Delivery Services or any other transportation, courier, or logistics work during the Relevant Period, other than Stonefield Logistics Group Inc., including: (a) the full name and address of each such entity or platform; (b) the dates during which You performed services for each, including the start date and end date (or indicate if ongoing); (c) the type of services performed for each entity or platform; (d) the total compensation received from each entity or platform, broken down by calendar year; (e) whether You were classified as an independent contractor or an employee by each such entity or platform, and whether You signed any independent contractor agreement or employment agreement with each; and (f) whether any such engagement overlapped in time with Your services for SLG—that is, whether You performed services for any other entity or platform during any period in which You were also performing Delivery Services for SLG—and if so, describe the extent of the overlap and whether You performed services for SLG and the other entity on the same day or during the same week.
INTERROGATORY NO. 12: Other Employment and Income Sources
For the Relevant Period, identify all sources of income, earnings, compensation, or benefits received by You other than SLG and any Delivery Platforms identified in Your response to Interrogatory No. 11, including: (a) any employment, whether part-time or full-time, with any employer, and for each, state the name and address of the employer, the dates of employment, Your job title or position, and the total compensation received, broken down by calendar year; (b) any self-employment, freelance work, gig work, or independent business activity of any kind, and for each, describe the nature of the work, the dates, and the total compensation or revenue received, broken down by calendar year; (c) any unemployment insurance benefits received from any state agency, including the dates received and the total amount; (d) any government assistance or benefits received, including Social Security benefits, disability benefits, food assistance, housing assistance, or any other form of public assistance; and (e) for each source identified, state the name of the employer, payor, or source, the dates of employment, engagement, or receipt, and the total compensation or benefits received during the Relevant Period.
INTERROGATORY NO. 13: Subcontracting Efforts
Describe each instance during the Relevant Period in which You sought to Subcontract, delegate, or assign any portion of the Delivery Services that You were engaged to perform for SLG to another person, including: (a) the date(s) of each such request or effort to Subcontract; (b) the SLG representative, manager, or dispatcher to whom each request was made, and the manner in which the request was communicated (e.g., in person, by telephone, by email, through RouteSync); (c) whether SLG's approval was granted or denied for each request; (d) if approved, identify the subcontractor by name, address, and telephone number, describe the dates and scope of the subcontracted services, and describe the compensation arrangement between You and the subcontractor, including the amount paid to the subcontractor for each subcontracted assignment; (e) if denied, describe the reason(s) given by SLG for the denial, the identity of the SLG representative who communicated the denial, and any follow-up Communications regarding the denial; and (f) if You never sought to Subcontract any portion of Your Delivery Services during the Relevant Period, state so explicitly and explain the reasons why You did not, including whether You believed You were permitted to do so under the ICOA and whether any SLG representative communicated any policy or position regarding Subcontracting.
INTERROGATORY NO. 14: RouteSync and Delivery Acceptance
Describe in detail Your use of SLG's RouteSync dispatch platform during the Relevant Period, including: (a) whether You had the ability to accept or decline individual delivery assignments offered to You through RouteSync, and if so, describe the process by which assignments were offered, accepted, or declined; (b) the approximate frequency with which You declined delivery assignments that were offered to You through RouteSync, expressed as a percentage of total offers received or as a number of declined assignments per week or per month; (c) Your approximate delivery acceptance rate over the Relevant Period (that is, the percentage of delivery assignments offered to You that You accepted), and how that rate compares to the 85% minimum acceptance rate referenced in the ICOA; (d) whether You were ever notified by SLG that Your acceptance rate had fallen below 85% or below any other threshold, and if so, describe each such notification, including the date, the method of notification, the SLG representative involved, the specific acceptance rate cited, and any consequences imposed or threatened, including any "performance review" or other process described in the ICOA; (e) if You were subject to a performance review or any other process as a result of a low acceptance rate, describe the process, the participants, the outcome, and any changes to Your delivery assignments or status that resulted; and (f) the extent to which RouteSync dictated, assigned, or suggested Your delivery route, sequence, or order of deliveries on any given day, versus the extent to which You were permitted to exercise Your own discretion in selecting and ordering Your delivery route, and describe any instances in which RouteSync's suggested route conflicted with Your preferred route and how You resolved such conflicts.
INTERROGATORY NO. 15: Route Discretion and Deviations
Describe the extent of discretion You exercised regarding delivery routes during the Relevant Period, including: (a) whether You followed the routes assigned, suggested, or generated by RouteSync, or whether You regularly selected Your own routes independent of RouteSync's suggestions; (b) the approximate frequency with which You deviated from RouteSync-suggested routes, expressed as a percentage of delivery days or total deliveries; (c) the reasons for any deviations from RouteSync-suggested routes, including but not limited to traffic conditions, road closures, personal preference, efficiency, customer requests, or any other reason; and (d) whether SLG ever disciplined You, counseled You, issued a warning to You, reduced Your delivery assignments, or took any other adverse action against You as a result of route deviations, and if so, describe each such instance in detail, including the date, the SLG representative involved, the nature of the adverse action, and the outcome.
INTERROGATORY NO. 16: Uniforms, Branding, and Equipment
Describe all uniforms, branded apparel, vehicle placards, vehicle magnets, decals, identification badges, handheld scanners, telematics devices, and any other equipment, supplies, or materials that SLG required You to use, wear, display, or maintain during the Relevant Period, including: (a) each specific item that was required; (b) whether SLG provided each item to You at no cost, at a subsidized cost, or whether You were required to purchase, rent, or otherwise obtain each item at Your own expense; (c) for any item You purchased or paid for, the cost of each item and the date of purchase; (d) whether You ever performed Delivery Services without wearing the required uniform, displaying the required SLG branding on Your vehicle, or using the required equipment, and if so, describe the circumstances of each such occasion, the approximate frequency, and any SLG response, discipline, or consequence that resulted; and (e) whether You were required to return any SLG-provided equipment or materials upon the termination of Your relationship with SLG, and if so, whether You returned such items and the date of return.
INTERROGATORY NO. 17: Training
Describe all training required or provided by SLG during the Relevant Period and throughout Your tenure with SLG, including: (a) the initial onboarding or orientation training program, including its total duration (understood by Defendant to be approximately 16 hours), the dates on which You completed the initial training, the location at which training was conducted, and the format (e.g., in-person, online, or a combination); (b) all quarterly or periodic training sessions required by SLG, including the approximate duration of each session (understood by Defendant to be approximately 4 hours per session), the dates on which You attended each session, and the location and format of each session; (c) the specific topics covered in each training session, including but not limited to safety protocols, customer service standards, delivery procedures, RouteSync operation, package handling, vehicle inspection, compliance with regulations, and any other subject matter; (d) whether attendance at each training session was mandatory or voluntary, and if mandatory, the consequences for failure to attend; (e) whether You were compensated for the time spent attending training sessions, and if so, the rate and amount of compensation received for training time, and if not, whether You believe You should have been compensated; and (f) the consequences, if any, imposed or threatened by SLG for failing to attend a required training session, including any warnings, suspension of delivery assignments, performance reviews, or termination.
INTERROGATORY NO. 18: GPS Tracking and Monitoring
Describe Your knowledge and experience with SLG's GPS telematics tracking and monitoring practices during the Relevant Period, including: (a) whether an SLG-provided or SLG-required telematics device was installed on Your vehicle(s), and if so, the type or brand of device and whether the device was installed by SLG personnel or by You; (b) the approximate date(s) on which the telematics device was first installed on each of Your vehicles; (c) whether You understood, at the time of installation and throughout the Relevant Period, that SLG monitored Your location, speed, driving behavior, stops, idle time, and route adherence through data transmitted by the telematics device; (d) whether You were ever contacted, counseled, warned, or disciplined by SLG based on data collected from the telematics device, and if so, describe each such instance in detail, including the date, the SLG representative involved, the specific data or behavior referenced, and any consequences or actions taken; and (e) whether You ever disabled, tampered with, disconnected, removed, or otherwise interfered with the operation of the telematics device, and if so, describe the circumstances, the date(s), the reason(s), and SLG's response.
INTERROGATORY NO. 19: Performance Reviews and Discipline
Describe each instance during the Relevant Period in which SLG took any of the following actions with respect to You: (a) conducted a formal or informal performance review, evaluation, or assessment of Your Delivery Services; (b) issued any warning, written or verbal counseling, corrective action notice, or similar communication regarding Your performance; (c) reduced the number or frequency of delivery assignments offered to You; (d) suspended Your ability to receive or accept delivery assignments through RouteSync or otherwise; or (e) took any other adverse action against You, including but not limited to fines, penalties, reassignment to a different hub, modification of Your per-delivery rate, or termination or threatened termination of the ICOA. For each such instance, state the date, identify the SLG representative(s) involved, describe the reason(s) given for the action, describe the substance of any Communications relating to the action, and describe the outcome or resolution, including any changes to Your delivery assignments, compensation, or status that resulted.
INTERROGATORY NO. 20: Non-Compete Provision
Describe Your understanding of the non-compete clause contained in the ICOA (which provides for a 12-month restriction within a 50-mile radius of the assigned distribution hub), including: (a) whether You were aware of the non-compete provision at the time You signed each version of the ICOA, and if so, describe Your understanding of the provision's scope, duration, and geographic limitation; (b) whether the non-compete provision affected, restricted, or deterred Your ability to perform delivery, logistics, courier, or transportation work for other entities during Your tenure with SLG, and if so, describe how and to what extent; (c) whether You performed delivery, logistics, courier, or transportation work for any entity that could be considered a competitor of SLG within a 50-mile radius of Your assigned distribution hub at any time during Your tenure with SLG or during the 12-month period following Your separation from SLG, and if so, identify each such entity and describe the nature and duration of the work performed; and (d) whether SLG ever sought to enforce, threaten to enforce, or communicate any intent to enforce the non-compete provision against You, and if so, describe each such instance, including the date, the SLG representative involved, the substance of the Communication, and the outcome.
INTERROGATORY NO. 21: Communications with Other SLG Drivers Regarding This Litigation
Identify each Communication You have had with any current or former SLG driver, service provider, or independent contractor regarding this lawsuit, the claims asserted herein, the possibility of filing a consent form to join this action as an opt-in plaintiff, or any facts relating to the allegations in this action, including: (a) the full name, last known address, telephone number, and email address of each such driver or person; (b) the date(s) of each Communication; (c) the method or medium of each Communication (e.g., in person, telephone, text message, email, social media platform, messaging application, or other means); (d) the substance and content of each Communication, described in sufficient detail to convey the information exchanged; and (e) whether each such Communication was initiated by You, by the other driver or person, by Your counsel at Hartwell & Brashear PLLC, or by any other person acting on Your behalf or at Your direction.
INTERROGATORY NO. 22: Communications with Plaintiff's Counsel
State the following with respect to Your engagement of legal counsel in connection with this action: (a) the date on which You first communicated with Hartwell & Brashear PLLC or any other attorney, law firm, legal aid organization, or legal services provider regarding potential claims against SLG, including wage-and-hour claims, misclassification claims, or any other claims; (b) the manner in which You became aware of Hartwell & Brashear PLLC, including whether You learned of the firm through an advertisement, a website, social media, a referral from another person, or any other means; (c) whether You were referred to Hartwell & Brashear PLLC by another person, and if so, identify that person by name, address, and telephone number, and describe the circumstances of the referral; (d) whether You have a written engagement agreement, retainer agreement, or representation agreement with Hartwell & Brashear PLLC, and if so, the date of execution of such agreement; and (e) the fee arrangement between You and Your counsel, including whether the engagement is on a contingency fee basis, and if so, the contingency fee percentage or structure, and whether You are responsible for any costs or expenses regardless of the outcome of this action.
INTERROGATORY NO. 23: Declarations and Opt-In Solicitation
Describe in detail any and all efforts that You or Your counsel at Hartwell & Brashear PLLC have undertaken to solicit, recruit, or encourage current or former SLG drivers to file opt-in consent forms to join this action as plaintiffs, including: (a) the methods of solicitation employed, including but not limited to social media postings or advertisements, direct personal contact, telephone calls, text messages, emails, mailers, flyers, online advertisements, attorney websites, or any other method; (b) the dates of each solicitation effort or campaign; (c) the total number of current or former SLG drivers contacted, directly or indirectly, in connection with solicitation efforts; (d) the total number of opt-in consent forms received to date; (e) the identity of each person who has signed an opt-in consent form, including full name, last known address, telephone number, and the date the consent form was signed; and (f) a description of any declarations, affidavits, or sworn statements obtained from current or former SLG drivers that have been or will be submitted in support of Plaintiff's Motion for Conditional Certification (filed July 14, 2025), including the identity of each declarant or affiant, the date of each declaration or affidavit, and a summary of the subject matter addressed therein.
INTERROGATORY NO. 24: Prior Litigation and Claims
State whether You have ever been involved in any of the following, at any time in Your life, whether as a party, a putative class member, or a witness: (a) a plaintiff, named plaintiff, class representative, lead plaintiff, or opt-in plaintiff in any lawsuit, class action, collective action, arbitration, mediation, administrative proceeding, or other legal claim or proceeding of any kind, including but not limited to wage-and-hour claims, employment discrimination claims, wrongful termination claims, personal injury claims, breach of contract claims, consumer protection claims, or any other type of claim; (b) a respondent, defendant, or adverse party in any such proceeding; or (c) the filing of a complaint, charge, claim, or petition with any federal, state, or local agency, including but not limited to the United States Department of Labor, the Equal Employment Opportunity Commission, the Texas Workforce Commission, any state department of labor, any workers' compensation board, or any other governmental agency. For each such matter, state the case caption or title, the case number or docket number, the name and location of the court or agency, the date filed or initiated, the nature of the claims asserted, the identity of all parties, the current status, and the outcome or resolution (including any settlement, judgment, dismissal, or withdrawal).
INTERROGATORY NO. 25: Damages Calculation
Describe in detail the factual and computational basis for all damages You seek in this action, both individually and on behalf of the putative collective, including: (a) the total amount of unpaid overtime compensation You allege is owed to You individually; (b) the specific time period and the total number of weeks for which You seek unpaid overtime compensation; (c) the regular rate of pay You contend should apply for purposes of calculating overtime, and the factual and legal basis for that rate (Defendant understands Plaintiff has alleged an effective hourly rate of approximately $21.50, derived by dividing average weekly pay of $1,247.00 by 58 hours per week); (d) the overtime rate You contend applies and the basis for that rate (Defendant understands Plaintiff has alleged an overtime rate of $32.25 per hour, calculated as 1.5 times the alleged regular rate of $21.50); (e) the average number of overtime hours per week You claim to have worked in excess of 40 hours (Defendant understands Plaintiff has alleged approximately 18 overtime hours per week, based on a claim of approximately 58 hours worked per week); (f) the specific calculation method used to arrive at Your individual damages figure, set forth in a step-by-step computation showing each variable and the mathematical operations applied; (g) any other categories of damages You seek in this action, including but not limited to liquidated damages under 29 U.S.C. § 216(b), statutory penalties, pre-judgment interest, post-judgment interest, attorneys' fees, costs, and any other relief; and (h) identify each Document, record, data source, expert report, or other material upon which You rely or intend to rely in computing or supporting Your damages, and for each, state whether it is currently in Your possession, custody, or control, or in the possession, custody, or control of a third party, and if a third party, identify that party.
Defendant Stonefield Logistics Group Inc. respectfully requests that Plaintiff Marcus Delano answer each of the foregoing interrogatories separately, fully, and under oath, within thirty (30) days of service, in accordance with Federal Rule of Civil Procedure 33. Defendant reserves the right to propound additional interrogatories as permitted by the Federal Rules of Civil Procedure, the Local Rules of the Northern District of Texas, and any orders of this Court.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Bernard Crawford State Bar No. 24078631 Responsible Partner
James Underwood State Bar No. 24112459 Lead Associate
Devon Archer State Bar No. 24126803 Working Associate
CALDERWOOD & HARKNESS LLP 2200 Ross Avenue, Suite 3600 Dallas, TX 75201 Telephone: (214) 756-4200 Facsimile: (214) 756-4201
Email: bcrawford@calderwoodharkness.com
Email: junderwood@calderwoodharkness.com
Email: darcher@calderwoodharkness.com
ATTORNEYS FOR DEFENDANT STONEFIELD LOGISTICS GROUP INC.
CERTIFICATE OF SERVICE
I hereby certify that on June 23, 2025, a true and correct copy of Defendant Stonefield Logistics Group Inc.'s First Set of Interrogatories to Plaintiff Marcus Delano (Interrogatory Nos. 1–25) was served upon all counsel of record via the Court's CM/ECF electronic filing system, which constitutes service upon the following:
Claudia Hartwell Jordan Brashear Hartwell & Brashear PLLC 500 N. Akard Street, Suite 1750 Dallas, TX 75201 Telephone: (214) 932-8100 Facsimile: (214) 932-8101
Email: chartwell@hartwellbrashear.com
Email: jbrashear@hartwellbrashear.com
Lead Counsel for Plaintiff Marcus Delano
________________________________________
Devon Archer
MARCUS DELANO, individually and on behalf of all others similarly situated,
<!-- indent:1 -->Plaintiff,<!-- /indent -->
Civil Action No. 3:25-cv-01847-RBC
v.
Hon. Rebecca Chen
STONEFIELD LOGISTICS GROUP INC., | U.S. District Judge
<!-- indent:1 -->Defendant.<!-- /indent --> | Hon. Timothy Farrell
U.S. Magistrate Judge

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

DEFINITIONS

INSTRUCTIONS

INTERROGATORIES

CALDERWOOD & HARKNESS LLP

ATTORNEYS FOR DEFENDANT STONEFIELD LOGISTICS GROUP INC.

CERTIFICATE OF SERVICE

Record

Parties

Dates

Amounts