1012-00004 · Stonefield Logistics Group · Discovery

first-set-rfps-to-plaintiff.docx DOCUMENT Finance & Banking

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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 REQUESTS FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF MARCUS DELANO

Defendant Stonefield Logistics Group Inc. ("Stonefield" or "SLG"), by and through its attorneys of record, Calderwood & Harkness LLP, hereby propounds its First Set of Requests for Production of Documents (Nos. 1–30) upon Plaintiff Marcus Delano ("Plaintiff" or "Delano"), pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure. Documents responsive to these Requests shall be produced within thirty (30) days of service of this First Set of Requests for Production, or at such other time as the parties may agree in writing or the Court may order. This First Set of Requests for Production is served upon Plaintiff this 23rd day of June, 2025.

I. DEFINITIONS

As used in these Requests for Production, the following terms shall have the meanings set forth below:

1. "You," "Your," and "Plaintiff" shall mean Marcus Delano, individually and in any representative capacity asserted in this action, and any person acting or purporting to act on his behalf, including but not limited to his attorneys, agents, representatives, accountants, tax preparers, financial advisors, family members, and any other person or entity acting at his direction or under his control.

2. "SLG," "Stonefield," "Defendant," or "the Company" shall mean Stonefield Logistics Group Inc., including its current and former officers, directors, employees, agents, subsidiaries, affiliates, predecessors, successors, and assigns.

3. "Document" or "Documents" shall have the broadest meaning ascribed to that term under Federal Rule of Civil Procedure 34(a) and shall include, without limitation, all writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information ("ESI"), and other data or data compilations stored in any medium from which information can be obtained, translated, or converted, if necessary, by the responding party through detection devices into reasonably usable form. The term includes, without limitation, all originals, drafts, revisions, and final versions of any such material, as well as all non-identical copies, whether different from the original by reason of any notation, underlining, highlighting, or other marking made on or attached to such copy.

4. "Communication" or "Communications" shall mean every manner or means of disclosure, exchange, or transfer of information, whether oral, written, or electronic, including but not limited to letters, memoranda, notes, emails, text messages (SMS, MMS, Westmark Software, or otherwise), instant messages, social media messages (including direct messages on any platform), voicemails, voice recordings, video messages, facsimile transmissions, and any other form of correspondence or information exchange, regardless of the medium or platform used.

5. "ICOA" shall mean the Independent Contractor Operating Agreement between Plaintiff and Stonefield Logistics Group Inc., in any version, including but not limited to version 1.0 (originally executed in 2018), version 2.0 (dated August 2020), and version 3.0 (dated January 2023), together with any amendment, addendum, side letter, exhibit, attachment, or modification thereto.

6. "Relevant Period" shall mean the period from April 30, 2022 through the present date, unless otherwise specified in a particular Request. Where a particular Request specifies a different time period, the time period stated in the Request shall control.

7. "Delivery Platform" shall mean any application, software system, service, or company through which delivery, courier, freight, transportation, or logistics services are offered, dispatched, scheduled, coordinated, or performed, including but not limited to SLG's RouteSync platform and any competing or third-party platform such as Ashbury Corporation, Aldermere Enterprises, Uber Freight, Strathmore Holdings, OnTrac, LaserShip, or any similar service.

8. "RouteSync" shall mean Stonefield Logistics Group Inc.'s proprietary dispatch and routing software platform, through which delivery routes, stops, and packages are assigned, tracked, and managed, and through which drivers accept or decline delivery assignments.

9. "Hub" or "Distribution Hub" shall mean any Stonefield distribution hub, warehouse, sorting facility, or staging area, including but not limited to HUB-01 (Fort Worth, TX, located at 1015 Railhead Parkway, Fort Worth, TX 76106) and all other SLG hubs and distribution facilities located across Texas, Oklahoma, Louisiana, and Arkansas.

10. "Person" shall mean any natural person, corporation, partnership, limited liability company, joint venture, association, trust, estate, governmental entity, agency, or any other legal or commercial entity.

11. "Concerning," "Regarding," "Relating to," or "In connection with" shall mean referring to, reflecting, describing, constituting, evidencing, comprising, mentioning, pertaining to, discussing, setting forth, summarizing, memorializing, or having any logical connection, whether direct or indirect, to the subject matter referenced.

12. "Identify" or "Identification" when used with respect to a Document shall mean stating the type of Document, the date of the Document, the author(s) and recipient(s) of the Document, a brief description of the subject matter of the Document, and the present location and custodian of the Document. When used with respect to a Person, "Identify" shall mean stating the Person's full name, last known address, telephone number, and, if applicable, the Person's relationship to any party or entity relevant to this action.

II. INSTRUCTIONS

1. Scope. These Requests seek documents within Plaintiff's possession, custody, or control. A document is within Plaintiff's "possession, custody, or control" if Plaintiff has the legal right or practical ability to obtain the document from any source, including but not limited to documents held by Plaintiff's agents, attorneys (to the extent not protected by attorney-client privilege or work-product doctrine), accountants, tax preparers, financial advisors, banks or financial institutions, insurance companies, family members, or any other person or entity on Plaintiff's behalf. Plaintiff is required to make a reasonable and diligent search for all responsive documents in all locations where such documents may be found, including any personal computers, laptops, tablets, smartphones, email accounts, cloud storage services, external drives, filing cabinets, and any other storage media.

2. Time Period. Unless otherwise specified in a particular Request, each Request covers the Relevant Period, which is defined as April 30, 2022 through the present date. Where a specific Request designates a different time period, the time period expressly stated in that Request shall govern.

3. Production Format. Documents shall be produced in the format specified in the parties' Joint Rule 26(f) Report filed on June 16, 2025, and in accordance with the ESI protocol agreed upon therein. To the extent no specific protocol applies to a particular category of documents, such documents shall be produced in their native format. If any responsive document was created or is maintained in electronic form, it shall be produced in its native electronic format, with all metadata preserved and intact.

4. Privilege Log. To the extent Plaintiff withholds any responsive document, or any portion thereof, on the basis of any claim of attorney-client privilege, work-product protection, or any other privilege or immunity from discovery, Plaintiff shall produce a privilege log in accordance with Federal Rule of Civil Procedure 26(b)(5)(A) and the Court's Scheduling Order entered June 20, 2025. The privilege log shall identify each document withheld with sufficient detail to enable Defendant to assess the applicability of the claimed privilege, including the date, author, recipient(s), general subject matter, and the specific basis for the privilege claim.

5. Continuing Obligation. Plaintiff's obligation to respond to these Requests is a continuing one pursuant to Federal Rule of Civil Procedure 26(e). If, after producing documents in response to these Requests, Plaintiff obtains, discovers, or creates additional documents responsive to any Request, Plaintiff shall promptly supplement its production with such additional documents.

6. Organization. Documents shall be produced as they are kept in the ordinary course of business, or shall be organized and labeled to correspond with each specific Request to which they are responsive, in accordance with Federal Rule of Civil Procedure 34(b)(2)(E).

7. Identification of Sources. For each document produced, Plaintiff shall identify the Request or Requests to which the document is responsive. Where a document is responsive to more than one Request, it need only be produced once, but Plaintiff shall indicate all Requests to which the document relates.

8. Objections. If Plaintiff objects to any Request, in whole or in part, Plaintiff shall state the objection with specificity and shall produce all responsive documents as to which no objection is made. An objection to any part of a Request shall not be deemed a basis for failing to respond to the remainder of the Request.

9. No Documents. If Plaintiff has no documents responsive to a particular Request, Plaintiff shall so state in writing, confirming that a diligent search has been conducted and that no responsive documents exist or are within Plaintiff's possession, custody, or control.

III. REQUESTS FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 1 — Independent Contractor Operating Agreements

All copies of any Independent Contractor Operating Agreement ("ICOA"), including any version (v1.0, v2.0, v3.0), amendment, addendum, side letter, exhibit, attachment, rider, or modification, between Plaintiff and Stonefield Logistics Group Inc., for the period from March 2021 (when Plaintiff first began performing delivery services for SLG) through September 2024 (when Plaintiff ceased performing such services). This Request includes, without limitation, all versions of the ICOA that were signed, executed, acknowledged, or offered to Plaintiff during that period, regardless of whether Plaintiff ultimately executed a particular version, as well as any redlined or marked-up drafts of any such agreement that may be in Plaintiff's possession.

REQUEST FOR PRODUCTION NO. 2 — Federal Tax Returns

Complete copies of Plaintiff's federal individual income tax returns (IRS Form 1040 and all schedules, attachments, and supporting documentation filed therewith, including but not limited to Schedule C — Profit or Loss from Business, Schedule SE — Self-Employment Tax, Schedule 1 — Additional Income and Adjustments to Income, and any other schedules or forms attached to or filed in connection with Plaintiff's Form 1040) for tax years 2021, 2022, 2023, and 2024. This Request includes both originally filed returns and any amended returns (Form 1040-X) filed for those tax years.

REQUEST FOR PRODUCTION NO. 3 — State Tax Returns

Complete copies of any and all Texas franchise tax filings, Texas Comptroller reports, or any state income tax returns filed by Plaintiff in any state, for tax years 2021, 2022, 2023, and 2024. This Request includes any returns or filings made in connection with any business entity formed or maintained by Plaintiff, as well as any state returns filed in any state other than Texas in which Plaintiff reported income or was required to file a return during the specified tax years.

REQUEST FOR PRODUCTION NO. 4 — Schedule C — Profit or Loss from Business (Specific Request)

All IRS Schedule C forms (Profit or Loss from Business — Sole Proprietorship) filed by Plaintiff for tax years 2021 through 2024, including any Schedule C reflecting income earned from delivery services, transportation services, courier services, freight services, or any independent contractor arrangement with any entity. This Request encompasses the complete Schedule C, including all parts and lines, as well as any supporting worksheets, depreciation schedules (IRS Form 4562), vehicle expense calculations, and records of business deductions claimed for vehicle expenses, insurance, fuel costs, maintenance and repair costs, equipment, supplies, and any other business-related expenses. These documents are relevant to Plaintiff's independent contractor status under the economic reality test, including whether Plaintiff reported income from SLG as self-employment income and claimed ordinary and necessary business deductions consistent with operating an independent business.

REQUEST FOR PRODUCTION NO. 5 — IRS Form 1099-NEC / 1099-MISC

All IRS Forms 1099-NEC (Nonemployee Compensation) and/or IRS Forms 1099-MISC (Miscellaneous Income) received by Plaintiff from any payor for tax years 2021, 2022, 2023, and 2024. This Request includes, without limitation, all such forms received from Stonefield Logistics Group Inc. and from any other delivery platform, transportation company, logistics company, courier service, or any other entity for which Plaintiff performed services during the specified tax years, regardless of the amount of compensation reported or the nature of the services performed.

REQUEST FOR PRODUCTION NO. 6 — Bank Account Statements

Complete monthly bank account statements for all checking accounts, savings accounts, and money market accounts held by Plaintiff, individually or jointly with any other person, for the Relevant Period (April 30, 2022 through the present), to the extent such statements reflect deposits, payments, transfers, or income received from SLG, any other delivery platform, any employer, or any other contracting entity. Plaintiff may redact transactions that are wholly unrelated to income, deposits, or payments from any employer, contracting entity, or delivery platform, provided that the redactions do not obscure the identity of any payor, the date of any deposit or payment, or the amount of any deposit or payment from such sources.

REQUEST FOR PRODUCTION NO. 7 — Payment Records from SLG

All documents reflecting payments, compensation, earnings, or any other form of remuneration received by Plaintiff from Stonefield Logistics Group Inc., including but not limited to payment stubs, settlement statements, earnings summaries, pay statements, direct deposit confirmations, checks (front and back), wire transfer confirmations, payment summaries, and any reports generated by RouteSync or any other SLG system reflecting amounts earned, amounts paid, deductions withheld, or bonuses awarded, for the period from March 2021 through September 2024.

REQUEST FOR PRODUCTION NO. 8 — Payment Records from Other Delivery Platforms or Employers

All documents reflecting payments, income, compensation, wages, earnings, or any other form of remuneration received by Plaintiff from any delivery platform, transportation company, logistics company, courier service, or any other employer or contracting entity (other than SLG) during the period from March 2021 through the present. This Request includes, without limitation, pay stubs, earnings statements, settlement summaries, direct deposit confirmations, checks, payment confirmations, and any similar records from any source of income, whether classified as employment income, independent contractor income, or otherwise. These documents are relevant to the entrepreneurial opportunity factor of the economic reality test and to the question of whether Plaintiff engaged in services for competing or alternative platforms during the period in which he performed services for SLG.

REQUEST FOR PRODUCTION NO. 9 — Contracts or Agreements with Other Delivery Platforms

All contracts, agreements, terms of service, independent contractor agreements, driver agreements, platform participation agreements, or similar documents between Plaintiff and any delivery platform, transportation company, logistics company, courier service, or similar entity other than SLG, for the period from March 2021 through the present. This Request includes any click-through or electronic agreements, as well as any amendments, modifications, or updates to such agreements. These documents are relevant to Plaintiff's multi-platform engagement, if any, and to the economic reality test factors concerning opportunity for profit or loss and entrepreneurial opportunity.

REQUEST FOR PRODUCTION NO. 10 — Subcontracting Agreements and Records

All documents relating to any efforts by Plaintiff to subcontract, delegate, assign, or otherwise transfer any delivery obligation or work obligation under the ICOA with SLG to any third party, including but not limited to: (a) any written or oral subcontracting agreement, arrangement, or understanding between Plaintiff and any third party; (b) any correspondence, communication, or request submitted to SLG, any hub manager, any SLG dispatcher, or any other SLG representative requesting approval or authorization to subcontract or delegate any delivery obligation; (c) any approvals, denials, or responses received from SLG in connection with any such request; and (d) any records reflecting the actual performance of delivery services by any substitute driver or subcontractor on Plaintiff's behalf. Plaintiff has alleged in his Complaint that zero subcontracting approvals were granted during his tenure with SLG; this Request seeks all documents that corroborate, contradict, or otherwise relate to that allegation.

REQUEST FOR PRODUCTION NO. 11 — Vehicle Ownership, Lease, and Financing Records

All documents relating to Plaintiff's ownership, lease, financing, or rental of any vehicle used in connection with delivery services performed for SLG, including but not limited to certificates of title, vehicle registration documents, lease agreements, loan agreements, purchase agreements, bills of sale, financing disclosure statements, and any related correspondence with dealerships, lessors, lenders, or rental agencies, for any cargo van, box truck, sprinter van, or other vehicle (model year 2015 or newer) used by Plaintiff during the period from March 2021 through September 2024. These documents are relevant to the economic reality test factor concerning Plaintiff's investment in equipment and facilities.

REQUEST FOR PRODUCTION NO. 12 — Vehicle Expense Records

All documents reflecting vehicle-related expenses incurred by Plaintiff in connection with delivery services performed for SLG or any other delivery platform, including but not limited to: fuel receipts and purchase records; maintenance and repair invoices and work orders; tire purchase receipts; oil change records; state or federal vehicle inspection records (including SLG safety inspections); vehicle registration fees; toll receipts and electronic toll records (e.g., TollTag, TxTag); parking expenses; car wash receipts; and any other costs attributable to the operation, upkeep, or maintenance of any vehicle used for delivery services, for the period from March 2021 through September 2024.

REQUEST FOR PRODUCTION NO. 13 — Vehicle Insurance Records

All documents relating to commercial or personal automobile insurance policies maintained by Plaintiff covering any vehicle used for delivery services performed for SLG, including but not limited to: policy declarations pages; certificates of insurance provided to SLG or any other entity; insurance applications; premium payment records and billing statements; endorsements or riders; and any claims filed under such policies, together with any related correspondence with insurance carriers or brokers, for the period from March 2021 through September 2024.

REQUEST FOR PRODUCTION NO. 14 — Business Entity Formation Documents

All documents relating to any business entity formed, organized, or maintained by Plaintiff, including but not limited to: articles of incorporation; certificates of formation; certificates of organization; partnership agreements; limited liability company operating agreements; assumed name certificates (d/b/a filings); applications for employer identification numbers (IRS Form SS-4 and EIN assignment letters); and any filings, reports, or correspondence with any Secretary of State, state tax authority, or other governmental agency, for the period from 2018 through the present. These documents are relevant to whether Plaintiff held himself out as operating an independent business and to the economic reality test factor concerning the nature of the working relationship.

REQUEST FOR PRODUCTION NO. 15 — Business Licenses and Permits

All business licenses, permits, certifications, or registrations obtained by Plaintiff in connection with the performance of delivery services, transportation services, courier services, logistics services, or any related business activity, including but not limited to commercial driver's licenses, DOT registrations, USDOT numbers, motor carrier permits, and local business permits or licenses, for the period from March 2021 through the present.

REQUEST FOR PRODUCTION NO. 16 — Business Expense Records (Non-Vehicle)

All documents reflecting business expenses incurred by Plaintiff (other than the vehicle expenses covered by Request No. 12), including but not limited to expenses for: equipment purchases or rentals; uniforms (whether SLG-branded or otherwise); hand-held scanners; mobile devices, smartphones, or tablets used for delivery services; software or application subscriptions; GPS devices or subscriptions; office supplies; marketing or advertising materials; business cards; website hosting or domain registration; signage; professional services (e.g., accounting, bookkeeping, legal); and any other costs incurred in connection with Plaintiff's delivery services business, for the period from March 2021 through September 2024.

REQUEST FOR PRODUCTION NO. 17 — Communications with Other SLG Drivers Regarding this Litigation

All communications, including but not limited to emails, text messages, instant messages, social media messages or posts (including posts in private or closed groups), direct messages, letters, and any other form of correspondence, between Plaintiff and any current or former SLG driver regarding this lawsuit, the claims asserted herein, potential opt-in participation or joinder, collective action certification, settlement discussions, or the terms and conditions of work at SLG as they relate to this litigation, from January 1, 2025 through the present.

REQUEST FOR PRODUCTION NO. 18 — Communications with Other SLG Drivers Regarding Working Conditions

All communications between Plaintiff and any current or former SLG driver regarding the terms, conditions, or circumstances of their work for SLG, including but not limited to discussions about: per-delivery pay rates (including the range of $14.50–$38.00 per delivery); hours of work; scheduling practices and policies; route assignments through RouteSync; GPS tracking and telematics monitoring; uniform and dress code requirements; vehicle placard and branding requirements; subcontracting policies and practices; the minimum acceptance rate requirement (85%); the non-compete clause; deactivation or termination practices; hub operations; any alleged employment relationship; and any other aspect of the working relationship between SLG drivers and the Company, for the Relevant Period (April 30, 2022 through the present).

REQUEST FOR PRODUCTION NO. 19 — Communications with Attorneys Regarding this Lawsuit (Pre-Retention)

All communications between Plaintiff and the law firm of Hartwell & Brashear PLLC, or any other attorney or law firm, regarding the potential filing of this lawsuit or any claim against SLG, prior to the date on which Plaintiff formally engaged or retained counsel to represent him in this action. This Request excludes communications that are protected by the attorney-client privilege, provided that Plaintiff identifies any such withheld communications on a privilege log in accordance with Federal Rule of Civil Procedure 26(b)(5)(A) and the Court's Scheduling Order entered June 20, 2025. This Request is intended to capture any pre-retention communications that do not constitute privileged legal advice, including, for example, initial inquiry communications, intake questionnaires, or marketing materials received from counsel prior to the establishment of an attorney-client relationship.

REQUEST FOR PRODUCTION NO. 20 — Social Media Posts and Online Activity

All social media posts, comments, messages, replies, stories, reels, profile descriptions, or online forum activity (including but not limited to posts on Kestrel Services Inc., Northpoint Services Inc., X (formerly Fenmore Solutions), Reddit, Westmark Health IT, Dunmore & Co., Crowne Albany Partners LLC, Penmark Technologies, Ridgeline Health IT, and any driver-focused forums, message boards, or online groups) by Plaintiff that reference SLG, Stonefield, Stonefield Logistics, RouteSync, driver classification, independent contractor status, misclassification, this litigation or any related legal proceeding, or working conditions at SLG, from April 30, 2022 through the present. This Request includes content posted by Plaintiff under any username, alias, or pseudonym, as well as any content that has been deleted, archived, or removed from public view but remains in Plaintiff's possession, custody, or control.

REQUEST FOR PRODUCTION NO. 21 — Training Records and Materials

All documents relating to training received by Plaintiff from SLG or any SLG representative, including but not limited to: training schedules and calendars; attendance records and sign-in sheets; completion certifications or certificates; training materials, handouts, or presentations; handbooks or manuals provided during training; safety manuals and protocols; customer service guides; RouteSync platform user guides or tutorials; any records of the 16-hour initial onboarding training; any records of the quarterly 4-hour training sessions; and any correspondence with SLG personnel concerning training requirements, for the period from March 2021 through September 2024.

REQUEST FOR PRODUCTION NO. 22 — Performance Reviews and Disciplinary Records

All documents relating to any performance review, evaluation, assessment, feedback, commendation, warning, reprimand, disciplinary action, corrective action, performance improvement plan, or "performance review" triggered by falling below the 85% minimum acceptance rate or any other performance metric applicable to Plaintiff, including but not limited to any communications with Dennis Faulkner (Hub Manager, Fort Worth HUB-01), or any other SLG personnel, supervisor, hub manager, or dispatcher, regarding Plaintiff's performance, compliance with SLG policies, customer complaints, delivery metrics, or any conduct issue, for the period from March 2021 through September 2024.

REQUEST FOR PRODUCTION NO. 23 — Scheduling and Availability Records

All documents reflecting Plaintiff's scheduling, availability, time-off requests, or work preferences in connection with delivery services for SLG, including but not limited to: any communications with SLG hub managers, dispatchers, or other personnel about Plaintiff's schedule preferences, requested days off, availability windows, shift selections, or changes to Plaintiff's working hours; any scheduling applications, portals, or tools used by Plaintiff; and any calendars, logs, or records maintained by Plaintiff reflecting the days and hours during which Plaintiff performed delivery services, for the period from March 2021 through September 2024. These documents are relevant to the degree of control exercised by SLG over Plaintiff's work and to whether Plaintiff exercised meaningful discretion over his scheduling within the 7:00 AM–8:00 PM Monday–Saturday delivery window described in the ICOA.

REQUEST FOR PRODUCTION NO. 24 — Route Selection and Deviation Records

All documents reflecting Plaintiff's selection, acceptance, rejection, modification, or deviation from delivery routes assigned through RouteSync, including but not limited to: any screenshots or records from the RouteSync platform reflecting route assignments, acceptance or rejection of routes, or completion of deliveries; any communications with SLG dispatchers, hub personnel, or route coordinators about route modifications, delivery refusals, stop resequencing, or route deviations; any records reflecting Plaintiff's exercise of discretion in determining the order, sequence, or manner of deliveries; and any records of routes completed by Plaintiff on a given day, for the period from March 2021 through September 2024.

REQUEST FOR PRODUCTION NO. 25 — Photographs of Uniforms, Vehicle, and Equipment

All photographs, images, screenshots, or videos in Plaintiff's possession, custody, or control depicting: (a) Plaintiff's vehicle, whether with or without SLG-branded vehicle placards, wraps, magnets, or other branding; (b) SLG-branded uniforms, shirts, jackets, hats, or other apparel worn by Plaintiff; (c) SLG-issued identification badges or credentials; (d) SLG-provided or SLG-required handheld scanners, barcode readers, or delivery devices; (e) telematics devices, GPS devices, or dashboard cameras installed in or on Plaintiff's vehicle; or (f) any other equipment, tools, or materials related to Plaintiff's delivery services for SLG. This Request includes photographs or images stored on any smartphone, tablet, computer, cloud storage service (e.g., Meridian Systems, Severin Industries Photos, Larkspur Technologies), or social media platform.

REQUEST FOR PRODUCTION NO. 26 — Declarations and Statements from Other Drivers

All declarations, affidavits, sworn statements, written statements, questionnaire responses, survey results, or similar materials from any current or former SLG driver, obtained, prepared, collected, or compiled by or on behalf of Plaintiff or Plaintiff's counsel, in connection with this lawsuit, the investigation of claims against SLG, or the Motion for Conditional Certification filed July 14, 2025, to the extent such materials are not protected by the work-product doctrine. To the extent Plaintiff or Plaintiff's counsel contend that any responsive materials are protected by the work-product doctrine, Plaintiff shall identify such materials on a privilege log in accordance with the instructions set forth above.

REQUEST FOR PRODUCTION NO. 27 — Correspondence with SLG (Non-Litigation)

All correspondence, communications, and written exchanges between Plaintiff and any officer, employee, agent, or representative of SLG, including but not limited to Margaret Hollis (Chief Operating Officer), Aaron Turcotte (Vice President, Driver Operations), Karen Lund (Regional Operations Manager), Dennis Faulkner (Hub Manager, Fort Worth HUB-01), and Trevor Sandoval (Senior Vice President, Legal & Compliance), concerning or relating to: the terms, conditions, or provisions of Plaintiff's ICOA; any pay dispute, payment inquiry, or compensation issue; Plaintiff's classification as an independent contractor; the working conditions applicable to Plaintiff's engagement; the termination, non-renewal, expiration, or cessation of Plaintiff's engagement with SLG; and any other subject relating to the business relationship between Plaintiff and SLG that is not otherwise covered by a specific Request above, for the period from March 2021 through the present.

REQUEST FOR PRODUCTION NO. 28 — Health Insurance, Benefits, and Retirement Account Records

All documents relating to health insurance, medical insurance, dental insurance, vision insurance, workers' compensation insurance, disability insurance (short-term or long-term), life insurance, retirement accounts (including but not limited to Individual Retirement Accounts, Simplified Employee Pension (SEP) IRAs, SIMPLE IRAs, 401(k) plans, Roth IRAs, and any employer-sponsored retirement plans), health savings accounts (HSAs), or any other employee or individual benefits obtained, procured, or maintained by Plaintiff, whether individually, through any employer, through any marketplace or exchange, or through any other entity or program, for the period from March 2021 through the present. These documents are relevant to the economic reality test factor of whether Plaintiff bore the typical hallmarks of an independent contractor, including the procurement and maintenance of his own benefits and insurance separate from any employer-provided benefits.

REQUEST FOR PRODUCTION NO. 29 — Documents Relating to SLG's Non-Compete Clause

All documents relating to the non-compete clause contained in Plaintiff's ICOA (providing for a twelve-month post-termination restriction within a fifty-mile radius of Plaintiff's assigned hub), including but not limited to: any communications between Plaintiff and any person regarding the enforceability, applicability, scope, or alleged violation of the non-compete provision; any legal advice or opinion received by Plaintiff regarding the non-compete clause (to the extent not protected by attorney-client privilege, with withheld documents identified on a privilege log); and any documents reflecting Plaintiff's efforts, attempts, or success in performing delivery services, transportation services, or similar work within fifty miles of the Fort Worth hub (HUB-01, located at 1015 Railhead Parkway, Fort Worth, TX 76106) after the cessation of Plaintiff's services with SLG in September 2024.

REQUEST FOR PRODUCTION NO. 30 — Miscellaneous Documents Supporting Claims or Damages

All documents not otherwise requested in Requests Nos. 1 through 29 above that Plaintiff intends to rely upon, offer into evidence, or reference in support of any claim, allegation, contention, or damages theory asserted in Plaintiff's Complaint filed April 30, 2025, or any amended complaint. This Request includes, without limitation, all documents supporting Plaintiff's allegations regarding: (a) the hours worked by Plaintiff (including the alleged average of 55–65 hours per week); (b) per-delivery compensation received and the method of its calculation; (c) overtime calculations and the alleged failure to pay overtime compensation (including the alleged $21.50 effective hourly rate, the alleged $32.25 FLSA overtime rate, and the alleged $193.50 in weekly unpaid overtime); (d) the degree of control exercised by SLG over Plaintiff and other drivers; (e) Plaintiff's standing and adequacy to represent a collective of approximately 1,187 similarly situated drivers; (f) any expert reports, analyses, or calculations prepared or obtained by or on behalf of Plaintiff; and (g) any other documents that Plaintiff may use to support any aspect of his case-in-chief or his opposition to any defense asserted by SLG.

CERTIFICATE OF SERVICE

I, Bernard Crawford, counsel for Defendant Stonefield Logistics Group Inc., hereby certify that on June 23, 2025, a true and correct copy of the foregoing Defendant Stonefield Logistics Group Inc.'s First Set of Requests for Production of Documents to Plaintiff Marcus Delano was served upon counsel for Plaintiff via the Court's CM/ECF electronic filing system, which will send notification of such filing to the following counsel of record:

Claudia Hartwell HARTWELL & BRASHEAR PLLC 500 N. Akard Street, Suite 1750 Dallas, TX 75201 chartwell@hartwellbrashear.com

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Bernard Crawford Texas Bar No. 24058713 bcrawford@calderwoodharkness.com

James Underwood Texas Bar No. 24092641 junderwood@calderwoodharkness.com

2200 Ross Avenue, Suite 3600 Dallas, TX 75201 Telephone: (214) 555-8200 Facsimile: (214) 555-8201

Attorneys for Defendant Stonefield Logistics Group Inc.

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

Plaintiff,

v.	Civil Action No. 3:25-cv-01847-RBC
STONEFIELD LOGISTICS GROUP INC.,	Hon. Rebecca Chen, U.S. District Judge

Hon. Timothy Farrell, U.S. Magistrate Judge

Defendant.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION
DEFENDANT STONEFIELD LOGISTICS GROUP INC.'S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF MARCUS DELANO
Defendant Stonefield Logistics Group Inc. ("Stonefield" or "SLG"), by and through its attorneys of record, Calderwood & Harkness LLP, hereby propounds its First Set of Requests for Production of Documents (Nos. 1–30) upon Plaintiff Marcus Delano ("Plaintiff" or "Delano"), pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure. Documents responsive to these Requests shall be produced within thirty (30) days of service of this First Set of Requests for Production, or at such other time as the parties may agree in writing or the Court may order. This First Set of Requests for Production is served upon Plaintiff this 23rd day of June, 2025.
I. DEFINITIONS
As used in these Requests for Production, the following terms shall have the meanings set forth below:
1.  "You," "Your," and "Plaintiff" shall mean Marcus Delano, individually and in any representative capacity asserted in this action, and any person acting or purporting to act on his behalf, including but not limited to his attorneys, agents, representatives, accountants, tax preparers, financial advisors, family members, and any other person or entity acting at his direction or under his control.
2.  "SLG," "Stonefield," "Defendant," or "the Company" shall mean Stonefield Logistics Group Inc., including its current and former officers, directors, employees, agents, subsidiaries, affiliates, predecessors, successors, and assigns.
3.  "Document" or "Documents" shall have the broadest meaning ascribed to that term under Federal Rule of Civil Procedure 34(a) and shall include, without limitation, all writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information ("ESI"), and other data or data compilations stored in any medium from which information can be obtained, translated, or converted, if necessary, by the responding party through detection devices into reasonably usable form. The term includes, without limitation, all originals, drafts, revisions, and final versions of any such material, as well as all non-identical copies, whether different from the original by reason of any notation, underlining, highlighting, or other marking made on or attached to such copy.
4.  "Communication" or "Communications" shall mean every manner or means of disclosure, exchange, or transfer of information, whether oral, written, or electronic, including but not limited to letters, memoranda, notes, emails, text messages (SMS, MMS, Westmark Software, or otherwise), instant messages, social media messages (including direct messages on any platform), voicemails, voice recordings, video messages, facsimile transmissions, and any other form of correspondence or information exchange, regardless of the medium or platform used.
5.  "ICOA" shall mean the Independent Contractor Operating Agreement between Plaintiff and Stonefield Logistics Group Inc., in any version, including but not limited to version 1.0 (originally executed in 2018), version 2.0 (dated August 2020), and version 3.0 (dated January 2023), together with any amendment, addendum, side letter, exhibit, attachment, or modification thereto.
6.  "Relevant Period" shall mean the period from April 30, 2022 through the present date, unless otherwise specified in a particular Request. Where a particular Request specifies a different time period, the time period stated in the Request shall control.
7.  "Delivery Platform" shall mean any application, software system, service, or company through which delivery, courier, freight, transportation, or logistics services are offered, dispatched, scheduled, coordinated, or performed, including but not limited to SLG's RouteSync platform and any competing or third-party platform such as Ashbury Corporation, Aldermere Enterprises, Uber Freight, Strathmore Holdings, OnTrac, LaserShip, or any similar service.
8.  "RouteSync" shall mean Stonefield Logistics Group Inc.'s proprietary dispatch and routing software platform, through which delivery routes, stops, and packages are assigned, tracked, and managed, and through which drivers accept or decline delivery assignments.
9.  "Hub" or "Distribution Hub" shall mean any Stonefield distribution hub, warehouse, sorting facility, or staging area, including but not limited to HUB-01 (Fort Worth, TX, located at 1015 Railhead Parkway, Fort Worth, TX 76106) and all other SLG hubs and distribution facilities located across Texas, Oklahoma, Louisiana, and Arkansas.
10.  "Person" shall mean any natural person, corporation, partnership, limited liability company, joint venture, association, trust, estate, governmental entity, agency, or any other legal or commercial entity.
11.  "Concerning," "Regarding," "Relating to," or "In connection with" shall mean referring to, reflecting, describing, constituting, evidencing, comprising, mentioning, pertaining to, discussing, setting forth, summarizing, memorializing, or having any logical connection, whether direct or indirect, to the subject matter referenced.
12.  "Identify" or "Identification" when used with respect to a Document shall mean stating the type of Document, the date of the Document, the author(s) and recipient(s) of the Document, a brief description of the subject matter of the Document, and the present location and custodian of the Document. When used with respect to a Person, "Identify" shall mean stating the Person's full name, last known address, telephone number, and, if applicable, the Person's relationship to any party or entity relevant to this action.
II. INSTRUCTIONS
1.  Scope. These Requests seek documents within Plaintiff's possession, custody, or control. A document is within Plaintiff's "possession, custody, or control" if Plaintiff has the legal right or practical ability to obtain the document from any source, including but not limited to documents held by Plaintiff's agents, attorneys (to the extent not protected by attorney-client privilege or work-product doctrine), accountants, tax preparers, financial advisors, banks or financial institutions, insurance companies, family members, or any other person or entity on Plaintiff's behalf. Plaintiff is required to make a reasonable and diligent search for all responsive documents in all locations where such documents may be found, including any personal computers, laptops, tablets, smartphones, email accounts, cloud storage services, external drives, filing cabinets, and any other storage media.
2.  Time Period. Unless otherwise specified in a particular Request, each Request covers the Relevant Period, which is defined as April 30, 2022 through the present date. Where a specific Request designates a different time period, the time period expressly stated in that Request shall govern.
3.  Production Format. Documents shall be produced in the format specified in the parties' Joint Rule 26(f) Report filed on June 16, 2025, and in accordance with the ESI protocol agreed upon therein. To the extent no specific protocol applies to a particular category of documents, such documents shall be produced in their native format. If any responsive document was created or is maintained in electronic form, it shall be produced in its native electronic format, with all metadata preserved and intact.
4.  Privilege Log. To the extent Plaintiff withholds any responsive document, or any portion thereof, on the basis of any claim of attorney-client privilege, work-product protection, or any other privilege or immunity from discovery, Plaintiff shall produce a privilege log in accordance with Federal Rule of Civil Procedure 26(b)(5)(A) and the Court's Scheduling Order entered June 20, 2025. The privilege log shall identify each document withheld with sufficient detail to enable Defendant to assess the applicability of the claimed privilege, including the date, author, recipient(s), general subject matter, and the specific basis for the privilege claim.
5.  Continuing Obligation. Plaintiff's obligation to respond to these Requests is a continuing one pursuant to Federal Rule of Civil Procedure 26(e). If, after producing documents in response to these Requests, Plaintiff obtains, discovers, or creates additional documents responsive to any Request, Plaintiff shall promptly supplement its production with such additional documents.
6.  Organization. Documents shall be produced as they are kept in the ordinary course of business, or shall be organized and labeled to correspond with each specific Request to which they are responsive, in accordance with Federal Rule of Civil Procedure 34(b)(2)(E).
7.  Identification of Sources. For each document produced, Plaintiff shall identify the Request or Requests to which the document is responsive. Where a document is responsive to more than one Request, it need only be produced once, but Plaintiff shall indicate all Requests to which the document relates.
8.  Objections. If Plaintiff objects to any Request, in whole or in part, Plaintiff shall state the objection with specificity and shall produce all responsive documents as to which no objection is made. An objection to any part of a Request shall not be deemed a basis for failing to respond to the remainder of the Request.
9.  No Documents. If Plaintiff has no documents responsive to a particular Request, Plaintiff shall so state in writing, confirming that a diligent search has been conducted and that no responsive documents exist or are within Plaintiff's possession, custody, or control.
III. REQUESTS FOR PRODUCTION
REQUEST FOR PRODUCTION NO. 1 — Independent Contractor Operating Agreements
All copies of any Independent Contractor Operating Agreement ("ICOA"), including any version (v1.0, v2.0, v3.0), amendment, addendum, side letter, exhibit, attachment, rider, or modification, between Plaintiff and Stonefield Logistics Group Inc., for the period from March 2021 (when Plaintiff first began performing delivery services for SLG) through September 2024 (when Plaintiff ceased performing such services). This Request includes, without limitation, all versions of the ICOA that were signed, executed, acknowledged, or offered to Plaintiff during that period, regardless of whether Plaintiff ultimately executed a particular version, as well as any redlined or marked-up drafts of any such agreement that may be in Plaintiff's possession.
REQUEST FOR PRODUCTION NO. 2 — Federal Tax Returns
Complete copies of Plaintiff's federal individual income tax returns (IRS Form 1040 and all schedules, attachments, and supporting documentation filed therewith, including but not limited to Schedule C — Profit or Loss from Business, Schedule SE — Self-Employment Tax, Schedule 1 — Additional Income and Adjustments to Income, and any other schedules or forms attached to or filed in connection with Plaintiff's Form 1040) for tax years 2021, 2022, 2023, and 2024. This Request includes both originally filed returns and any amended returns (Form 1040-X) filed for those tax years.
REQUEST FOR PRODUCTION NO. 3 — State Tax Returns
Complete copies of any and all Texas franchise tax filings, Texas Comptroller reports, or any state income tax returns filed by Plaintiff in any state, for tax years 2021, 2022, 2023, and 2024. This Request includes any returns or filings made in connection with any business entity formed or maintained by Plaintiff, as well as any state returns filed in any state other than Texas in which Plaintiff reported income or was required to file a return during the specified tax years.
REQUEST FOR PRODUCTION NO. 4 — Schedule C — Profit or Loss from Business (Specific Request)
All IRS Schedule C forms (Profit or Loss from Business — Sole Proprietorship) filed by Plaintiff for tax years 2021 through 2024, including any Schedule C reflecting income earned from delivery services, transportation services, courier services, freight services, or any independent contractor arrangement with any entity. This Request encompasses the complete Schedule C, including all parts and lines, as well as any supporting worksheets, depreciation schedules (IRS Form 4562), vehicle expense calculations, and records of business deductions claimed for vehicle expenses, insurance, fuel costs, maintenance and repair costs, equipment, supplies, and any other business-related expenses. These documents are relevant to Plaintiff's independent contractor status under the economic reality test, including whether Plaintiff reported income from SLG as self-employment income and claimed ordinary and necessary business deductions consistent with operating an independent business.
REQUEST FOR PRODUCTION NO. 5 — IRS Form 1099-NEC / 1099-MISC
All IRS Forms 1099-NEC (Nonemployee Compensation) and/or IRS Forms 1099-MISC (Miscellaneous Income) received by Plaintiff from any payor for tax years 2021, 2022, 2023, and 2024. This Request includes, without limitation, all such forms received from Stonefield Logistics Group Inc. and from any other delivery platform, transportation company, logistics company, courier service, or any other entity for which Plaintiff performed services during the specified tax years, regardless of the amount of compensation reported or the nature of the services performed.
REQUEST FOR PRODUCTION NO. 6 — Bank Account Statements
Complete monthly bank account statements for all checking accounts, savings accounts, and money market accounts held by Plaintiff, individually or jointly with any other person, for the Relevant Period (April 30, 2022 through the present), to the extent such statements reflect deposits, payments, transfers, or income received from SLG, any other delivery platform, any employer, or any other contracting entity. Plaintiff may redact transactions that are wholly unrelated to income, deposits, or payments from any employer, contracting entity, or delivery platform, provided that the redactions do not obscure the identity of any payor, the date of any deposit or payment, or the amount of any deposit or payment from such sources.
REQUEST FOR PRODUCTION NO. 7 — Payment Records from SLG
All documents reflecting payments, compensation, earnings, or any other form of remuneration received by Plaintiff from Stonefield Logistics Group Inc., including but not limited to payment stubs, settlement statements, earnings summaries, pay statements, direct deposit confirmations, checks (front and back), wire transfer confirmations, payment summaries, and any reports generated by RouteSync or any other SLG system reflecting amounts earned, amounts paid, deductions withheld, or bonuses awarded, for the period from March 2021 through September 2024.
REQUEST FOR PRODUCTION NO. 8 — Payment Records from Other Delivery Platforms or Employers
All documents reflecting payments, income, compensation, wages, earnings, or any other form of remuneration received by Plaintiff from any delivery platform, transportation company, logistics company, courier service, or any other employer or contracting entity (other than SLG) during the period from March 2021 through the present. This Request includes, without limitation, pay stubs, earnings statements, settlement summaries, direct deposit confirmations, checks, payment confirmations, and any similar records from any source of income, whether classified as employment income, independent contractor income, or otherwise. These documents are relevant to the entrepreneurial opportunity factor of the economic reality test and to the question of whether Plaintiff engaged in services for competing or alternative platforms during the period in which he performed services for SLG.
REQUEST FOR PRODUCTION NO. 9 — Contracts or Agreements with Other Delivery Platforms
All contracts, agreements, terms of service, independent contractor agreements, driver agreements, platform participation agreements, or similar documents between Plaintiff and any delivery platform, transportation company, logistics company, courier service, or similar entity other than SLG, for the period from March 2021 through the present. This Request includes any click-through or electronic agreements, as well as any amendments, modifications, or updates to such agreements. These documents are relevant to Plaintiff's multi-platform engagement, if any, and to the economic reality test factors concerning opportunity for profit or loss and entrepreneurial opportunity.
REQUEST FOR PRODUCTION NO. 10 — Subcontracting Agreements and Records
All documents relating to any efforts by Plaintiff to subcontract, delegate, assign, or otherwise transfer any delivery obligation or work obligation under the ICOA with SLG to any third party, including but not limited to: (a) any written or oral subcontracting agreement, arrangement, or understanding between Plaintiff and any third party; (b) any correspondence, communication, or request submitted to SLG, any hub manager, any SLG dispatcher, or any other SLG representative requesting approval or authorization to subcontract or delegate any delivery obligation; (c) any approvals, denials, or responses received from SLG in connection with any such request; and (d) any records reflecting the actual performance of delivery services by any substitute driver or subcontractor on Plaintiff's behalf. Plaintiff has alleged in his Complaint that zero subcontracting approvals were granted during his tenure with SLG; this Request seeks all documents that corroborate, contradict, or otherwise relate to that allegation.
REQUEST FOR PRODUCTION NO. 11 — Vehicle Ownership, Lease, and Financing Records
All documents relating to Plaintiff's ownership, lease, financing, or rental of any vehicle used in connection with delivery services performed for SLG, including but not limited to certificates of title, vehicle registration documents, lease agreements, loan agreements, purchase agreements, bills of sale, financing disclosure statements, and any related correspondence with dealerships, lessors, lenders, or rental agencies, for any cargo van, box truck, sprinter van, or other vehicle (model year 2015 or newer) used by Plaintiff during the period from March 2021 through September 2024. These documents are relevant to the economic reality test factor concerning Plaintiff's investment in equipment and facilities.
REQUEST FOR PRODUCTION NO. 12 — Vehicle Expense Records
All documents reflecting vehicle-related expenses incurred by Plaintiff in connection with delivery services performed for SLG or any other delivery platform, including but not limited to: fuel receipts and purchase records; maintenance and repair invoices and work orders; tire purchase receipts; oil change records; state or federal vehicle inspection records (including SLG safety inspections); vehicle registration fees; toll receipts and electronic toll records (e.g., TollTag, TxTag); parking expenses; car wash receipts; and any other costs attributable to the operation, upkeep, or maintenance of any vehicle used for delivery services, for the period from March 2021 through September 2024.
REQUEST FOR PRODUCTION NO. 13 — Vehicle Insurance Records
All documents relating to commercial or personal automobile insurance policies maintained by Plaintiff covering any vehicle used for delivery services performed for SLG, including but not limited to: policy declarations pages; certificates of insurance provided to SLG or any other entity; insurance applications; premium payment records and billing statements; endorsements or riders; and any claims filed under such policies, together with any related correspondence with insurance carriers or brokers, for the period from March 2021 through September 2024.
REQUEST FOR PRODUCTION NO. 14 — Business Entity Formation Documents
All documents relating to any business entity formed, organized, or maintained by Plaintiff, including but not limited to: articles of incorporation; certificates of formation; certificates of organization; partnership agreements; limited liability company operating agreements; assumed name certificates (d/b/a filings); applications for employer identification numbers (IRS Form SS-4 and EIN assignment letters); and any filings, reports, or correspondence with any Secretary of State, state tax authority, or other governmental agency, for the period from 2018 through the present. These documents are relevant to whether Plaintiff held himself out as operating an independent business and to the economic reality test factor concerning the nature of the working relationship.
REQUEST FOR PRODUCTION NO. 15 — Business Licenses and Permits
All business licenses, permits, certifications, or registrations obtained by Plaintiff in connection with the performance of delivery services, transportation services, courier services, logistics services, or any related business activity, including but not limited to commercial driver's licenses, DOT registrations, USDOT numbers, motor carrier permits, and local business permits or licenses, for the period from March 2021 through the present.
REQUEST FOR PRODUCTION NO. 16 — Business Expense Records (Non-Vehicle)
All documents reflecting business expenses incurred by Plaintiff (other than the vehicle expenses covered by Request No. 12), including but not limited to expenses for: equipment purchases or rentals; uniforms (whether SLG-branded or otherwise); hand-held scanners; mobile devices, smartphones, or tablets used for delivery services; software or application subscriptions; GPS devices or subscriptions; office supplies; marketing or advertising materials; business cards; website hosting or domain registration; signage; professional services (e.g., accounting, bookkeeping, legal); and any other costs incurred in connection with Plaintiff's delivery services business, for the period from March 2021 through September 2024.
REQUEST FOR PRODUCTION NO. 17 — Communications with Other SLG Drivers Regarding this Litigation
All communications, including but not limited to emails, text messages, instant messages, social media messages or posts (including posts in private or closed groups), direct messages, letters, and any other form of correspondence, between Plaintiff and any current or former SLG driver regarding this lawsuit, the claims asserted herein, potential opt-in participation or joinder, collective action certification, settlement discussions, or the terms and conditions of work at SLG as they relate to this litigation, from January 1, 2025 through the present.
REQUEST FOR PRODUCTION NO. 18 — Communications with Other SLG Drivers Regarding Working Conditions
All communications between Plaintiff and any current or former SLG driver regarding the terms, conditions, or circumstances of their work for SLG, including but not limited to discussions about: per-delivery pay rates (including the range of $14.50–$38.00 per delivery); hours of work; scheduling practices and policies; route assignments through RouteSync; GPS tracking and telematics monitoring; uniform and dress code requirements; vehicle placard and branding requirements; subcontracting policies and practices; the minimum acceptance rate requirement (85%); the non-compete clause; deactivation or termination practices; hub operations; any alleged employment relationship; and any other aspect of the working relationship between SLG drivers and the Company, for the Relevant Period (April 30, 2022 through the present).
REQUEST FOR PRODUCTION NO. 19 — Communications with Attorneys Regarding this Lawsuit (Pre-Retention)
All communications between Plaintiff and the law firm of Hartwell & Brashear PLLC, or any other attorney or law firm, regarding the potential filing of this lawsuit or any claim against SLG, prior to the date on which Plaintiff formally engaged or retained counsel to represent him in this action. This Request excludes communications that are protected by the attorney-client privilege, provided that Plaintiff identifies any such withheld communications on a privilege log in accordance with Federal Rule of Civil Procedure 26(b)(5)(A) and the Court's Scheduling Order entered June 20, 2025. This Request is intended to capture any pre-retention communications that do not constitute privileged legal advice, including, for example, initial inquiry communications, intake questionnaires, or marketing materials received from counsel prior to the establishment of an attorney-client relationship.
REQUEST FOR PRODUCTION NO. 20 — Social Media Posts and Online Activity
All social media posts, comments, messages, replies, stories, reels, profile descriptions, or online forum activity (including but not limited to posts on Kestrel Services Inc., Northpoint Services Inc., X (formerly Fenmore Solutions), Reddit, Westmark Health IT, Dunmore & Co., Crowne Albany Partners LLC, Penmark Technologies, Ridgeline Health IT, and any driver-focused forums, message boards, or online groups) by Plaintiff that reference SLG, Stonefield, Stonefield Logistics, RouteSync, driver classification, independent contractor status, misclassification, this litigation or any related legal proceeding, or working conditions at SLG, from April 30, 2022 through the present. This Request includes content posted by Plaintiff under any username, alias, or pseudonym, as well as any content that has been deleted, archived, or removed from public view but remains in Plaintiff's possession, custody, or control.
REQUEST FOR PRODUCTION NO. 21 — Training Records and Materials
All documents relating to training received by Plaintiff from SLG or any SLG representative, including but not limited to: training schedules and calendars; attendance records and sign-in sheets; completion certifications or certificates; training materials, handouts, or presentations; handbooks or manuals provided during training; safety manuals and protocols; customer service guides; RouteSync platform user guides or tutorials; any records of the 16-hour initial onboarding training; any records of the quarterly 4-hour training sessions; and any correspondence with SLG personnel concerning training requirements, for the period from March 2021 through September 2024.
REQUEST FOR PRODUCTION NO. 22 — Performance Reviews and Disciplinary Records
All documents relating to any performance review, evaluation, assessment, feedback, commendation, warning, reprimand, disciplinary action, corrective action, performance improvement plan, or "performance review" triggered by falling below the 85% minimum acceptance rate or any other performance metric applicable to Plaintiff, including but not limited to any communications with Dennis Faulkner (Hub Manager, Fort Worth HUB-01), or any other SLG personnel, supervisor, hub manager, or dispatcher, regarding Plaintiff's performance, compliance with SLG policies, customer complaints, delivery metrics, or any conduct issue, for the period from March 2021 through September 2024.
REQUEST FOR PRODUCTION NO. 23 — Scheduling and Availability Records
All documents reflecting Plaintiff's scheduling, availability, time-off requests, or work preferences in connection with delivery services for SLG, including but not limited to: any communications with SLG hub managers, dispatchers, or other personnel about Plaintiff's schedule preferences, requested days off, availability windows, shift selections, or changes to Plaintiff's working hours; any scheduling applications, portals, or tools used by Plaintiff; and any calendars, logs, or records maintained by Plaintiff reflecting the days and hours during which Plaintiff performed delivery services, for the period from March 2021 through September 2024. These documents are relevant to the degree of control exercised by SLG over Plaintiff's work and to whether Plaintiff exercised meaningful discretion over his scheduling within the 7:00 AM–8:00 PM Monday–Saturday delivery window described in the ICOA.
REQUEST FOR PRODUCTION NO. 24 — Route Selection and Deviation Records
All documents reflecting Plaintiff's selection, acceptance, rejection, modification, or deviation from delivery routes assigned through RouteSync, including but not limited to: any screenshots or records from the RouteSync platform reflecting route assignments, acceptance or rejection of routes, or completion of deliveries; any communications with SLG dispatchers, hub personnel, or route coordinators about route modifications, delivery refusals, stop resequencing, or route deviations; any records reflecting Plaintiff's exercise of discretion in determining the order, sequence, or manner of deliveries; and any records of routes completed by Plaintiff on a given day, for the period from March 2021 through September 2024.
REQUEST FOR PRODUCTION NO. 25 — Photographs of Uniforms, Vehicle, and Equipment
All photographs, images, screenshots, or videos in Plaintiff's possession, custody, or control depicting: (a) Plaintiff's vehicle, whether with or without SLG-branded vehicle placards, wraps, magnets, or other branding; (b) SLG-branded uniforms, shirts, jackets, hats, or other apparel worn by Plaintiff; (c) SLG-issued identification badges or credentials; (d) SLG-provided or SLG-required handheld scanners, barcode readers, or delivery devices; (e) telematics devices, GPS devices, or dashboard cameras installed in or on Plaintiff's vehicle; or (f) any other equipment, tools, or materials related to Plaintiff's delivery services for SLG. This Request includes photographs or images stored on any smartphone, tablet, computer, cloud storage service (e.g., Meridian Systems, Severin Industries Photos, Larkspur Technologies), or social media platform.
REQUEST FOR PRODUCTION NO. 26 — Declarations and Statements from Other Drivers
All declarations, affidavits, sworn statements, written statements, questionnaire responses, survey results, or similar materials from any current or former SLG driver, obtained, prepared, collected, or compiled by or on behalf of Plaintiff or Plaintiff's counsel, in connection with this lawsuit, the investigation of claims against SLG, or the Motion for Conditional Certification filed July 14, 2025, to the extent such materials are not protected by the work-product doctrine. To the extent Plaintiff or Plaintiff's counsel contend that any responsive materials are protected by the work-product doctrine, Plaintiff shall identify such materials on a privilege log in accordance with the instructions set forth above.
REQUEST FOR PRODUCTION NO. 27 — Correspondence with SLG (Non-Litigation)
All correspondence, communications, and written exchanges between Plaintiff and any officer, employee, agent, or representative of SLG, including but not limited to Margaret Hollis (Chief Operating Officer), Aaron Turcotte (Vice President, Driver Operations), Karen Lund (Regional Operations Manager), Dennis Faulkner (Hub Manager, Fort Worth HUB-01), and Trevor Sandoval (Senior Vice President, Legal & Compliance), concerning or relating to: the terms, conditions, or provisions of Plaintiff's ICOA; any pay dispute, payment inquiry, or compensation issue; Plaintiff's classification as an independent contractor; the working conditions applicable to Plaintiff's engagement; the termination, non-renewal, expiration, or cessation of Plaintiff's engagement with SLG; and any other subject relating to the business relationship between Plaintiff and SLG that is not otherwise covered by a specific Request above, for the period from March 2021 through the present.
REQUEST FOR PRODUCTION NO. 28 — Health Insurance, Benefits, and Retirement Account Records
All documents relating to health insurance, medical insurance, dental insurance, vision insurance, workers' compensation insurance, disability insurance (short-term or long-term), life insurance, retirement accounts (including but not limited to Individual Retirement Accounts, Simplified Employee Pension (SEP) IRAs, SIMPLE IRAs, 401(k) plans, Roth IRAs, and any employer-sponsored retirement plans), health savings accounts (HSAs), or any other employee or individual benefits obtained, procured, or maintained by Plaintiff, whether individually, through any employer, through any marketplace or exchange, or through any other entity or program, for the period from March 2021 through the present. These documents are relevant to the economic reality test factor of whether Plaintiff bore the typical hallmarks of an independent contractor, including the procurement and maintenance of his own benefits and insurance separate from any employer-provided benefits.
REQUEST FOR PRODUCTION NO. 29 — Documents Relating to SLG's Non-Compete Clause
All documents relating to the non-compete clause contained in Plaintiff's ICOA (providing for a twelve-month post-termination restriction within a fifty-mile radius of Plaintiff's assigned hub), including but not limited to: any communications between Plaintiff and any person regarding the enforceability, applicability, scope, or alleged violation of the non-compete provision; any legal advice or opinion received by Plaintiff regarding the non-compete clause (to the extent not protected by attorney-client privilege, with withheld documents identified on a privilege log); and any documents reflecting Plaintiff's efforts, attempts, or success in performing delivery services, transportation services, or similar work within fifty miles of the Fort Worth hub (HUB-01, located at 1015 Railhead Parkway, Fort Worth, TX 76106) after the cessation of Plaintiff's services with SLG in September 2024.
REQUEST FOR PRODUCTION NO. 30 — Miscellaneous Documents Supporting Claims or Damages
All documents not otherwise requested in Requests Nos. 1 through 29 above that Plaintiff intends to rely upon, offer into evidence, or reference in support of any claim, allegation, contention, or damages theory asserted in Plaintiff's Complaint filed April 30, 2025, or any amended complaint. This Request includes, without limitation, all documents supporting Plaintiff's allegations regarding: (a) the hours worked by Plaintiff (including the alleged average of 55–65 hours per week); (b) per-delivery compensation received and the method of its calculation; (c) overtime calculations and the alleged failure to pay overtime compensation (including the alleged $21.50 effective hourly rate, the alleged $32.25 FLSA overtime rate, and the alleged $193.50 in weekly unpaid overtime); (d) the degree of control exercised by SLG over Plaintiff and other drivers; (e) Plaintiff's standing and adequacy to represent a collective of approximately 1,187 similarly situated drivers; (f) any expert reports, analyses, or calculations prepared or obtained by or on behalf of Plaintiff; and (g) any other documents that Plaintiff may use to support any aspect of his case-in-chief or his opposition to any defense asserted by SLG.
CERTIFICATE OF SERVICE
I, Bernard Crawford, counsel for Defendant Stonefield Logistics Group Inc., hereby certify that on June 23, 2025, a true and correct copy of the foregoing Defendant Stonefield Logistics Group Inc.'s First Set of Requests for Production of Documents to Plaintiff Marcus Delano was served upon counsel for Plaintiff via the Court's CM/ECF electronic filing system, which will send notification of such filing to the following counsel of record:
Claudia Hartwell HARTWELL & BRASHEAR PLLC 500 N. Akard Street, Suite 1750 Dallas, TX 75201 chartwell@hartwellbrashear.com
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Bernard Crawford Texas Bar No. 24058713 bcrawford@calderwoodharkness.com
James Underwood Texas Bar No. 24092641 junderwood@calderwoodharkness.com
2200 Ross Avenue, Suite 3600 Dallas, TX 75201 Telephone: (214) 555-8200 Facsimile: (214) 555-8201
Attorneys for Defendant Stonefield Logistics Group Inc.
MARCUS DELANO, individually and on behalf of all others similarly situated,
Plaintiff,
v. | Civil Action No. 3:25-cv-01847-RBC
STONEFIELD LOGISTICS GROUP INC., | Hon. Rebecca Chen, U.S. District Judge
Hon. Timothy Farrell, U.S. Magistrate Judge
Defendant.

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

I. DEFINITIONS

II. INSTRUCTIONS

III. REQUESTS FOR PRODUCTION

CERTIFICATE OF SERVICE

CALDERWOOD & HARKNESS LLP

Record

Parties

Dates

Amounts