1012-00004 · Stonefield Logistics Group · Expert Engagement

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EXPERT RETENTION AGREEMENT

Between

Calderwood & Harkness LLP (on behalf of Stonefield Logistics Group Inc.)

and

Corbin Risk Advisors LLC

Dated as of May 8, 2025

C&H Matter No. 1012-00004

Delano v. Stonefield Logistics Group Inc. Case No. 3:25-cv-01847-RBC United States District Court for the Northern District of Texas, Dallas Division

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EXPERT RETENTION AGREEMENT

This Expert Retention Agreement (this "Agreement") is made and entered into as of May 8, 2025 (the "Effective Date"), by and between:

Calderwood & Harkness LLP, a limited liability partnership organized and existing under the laws of the State of New York, with offices at 2200 Ross Avenue, Suite 3600, Dallas, Texas 75201 ("Retaining Counsel" or "C&H"), acting on behalf of its client Stonefield Logistics Group Inc., a corporation organized and existing under the laws of the State of Delaware, with its principal place of business and corporate headquarters at 4200 Commerce Gateway Blvd., Suite 800, Irving, Texas 75039 (the "Client" or "SLG");

and

Corbin Risk Advisors LLC, a limited liability company organized and existing under the laws of the Commonwealth of Virginia, with its principal offices at 1901 N. Moore Street, Suite 1020, Arlington, Virginia 22209 (the "Consultant" or "CRA").

C&H and CRA are each referred to herein individually as a "Party" and collectively as the "Parties."

RECITALS. WHEREAS:

A. C&H represents SLG in the defense of a collective action filed under the Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq. ("FLSA"), and the Texas Payday Law, Tex. Lab. Code Ann. §§ 61.001 et seq., captioned Delano v. Stonefield Logistics Group Inc., Case No. 3:25-cv-01847-RBC, pending before the Honorable Rebecca Chen, United States District Judge, in the United States District Court for the Northern District of Texas, Dallas Division (the "Litigation");

B. The named plaintiff in the Litigation, Marcus Delano, a former delivery driver who performed services for SLG, alleges that SLG misclassified approximately 1,187 delivery drivers as independent contractors rather than employees, thereby depriving such drivers of overtime compensation in violation of the FLSA and applicable Texas law. Plaintiff seeks conditional certification of a collective comprising all individuals who performed delivery driving services for SLG pursuant to an Independent Contractor Operating Agreement ("ICOA") during the period from April 30, 2022 through the date of final judgment in the Litigation;

C. C&H desires to retain CRA to provide expert economic and statistical analysis services in support of SLG's defense of the Litigation, including but not limited to analysis relevant to the conditional certification phase and the merits phase of the Litigation, and CRA desires to provide such services on the terms and conditions set forth herein;

D. CRA, through its lead consultant Dr. Priya Ramanathan, a labor economist with extensive experience in FLSA collective action and worker classification matters, possesses the requisite expertise, qualifications, and resources to provide the economic and statistical analysis services required in connection with the Litigation; and

E. C&H and CRA desire to set forth the terms and conditions governing CRA's engagement, including the scope of services, compensation, confidentiality obligations, and related matters.

NOW, THEREFORE, in consideration of the mutual covenants and agreements set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties agree as follows:

SECTION 1: ENGAGEMENT AND SCOPE OF SERVICES

1.1 Retention. C&H hereby retains CRA, and CRA hereby accepts the retention, to serve as expert consultant and, as may be required by C&H in connection with the Litigation, as a testifying expert witness, on the terms and subject to the conditions set forth in this Agreement. CRA's lead consultant for this engagement shall be Dr. Priya Ramanathan (the "Lead Consultant"). Dr. Ramanathan shall have primary responsibility for all substantive work performed by CRA under this Agreement and shall serve as the principal point of contact between CRA and C&H. CRA may assign additional associate-level consultants and analysts to the engagement as reasonably necessary to fulfill its obligations hereunder, provided that any such assignment shall be subject to C&H's prior written approval, which shall not be unreasonably withheld.

1.2 Scope of Services — Conditional Certification Phase

During the conditional certification phase of the Litigation, CRA shall perform the following services at C&H's direction:

(a) Statistical and economic analysis of whether SLG's approximately 1,187 delivery drivers who executed ICOAs during the relevant period (April 30, 2022 through the present) are "similarly situated" for purposes of FLSA conditional certification under 29 U.S.C. § 216(b), including analysis of the degree of individualized variation among the driver population;

(b) Analysis of variance in key operational and economic metrics across the driver population, including but not limited to: (i) weekly hours worked; (ii) gross pay and per-delivery compensation; (iii) delivery acceptance rates, measured against the 85% minimum acceptance rate per rolling 30-day period specified in the ICOAs; (iv) route deviation frequency; and (v) multi-platform engagement (i.e., the extent to which drivers simultaneously performed delivery services for other companies or platforms during the relevant period), with such analyses conducted across and within SLG's fourteen (14) distribution hubs located in Texas, Oklahoma, Louisiana, and Arkansas;

(c) Analysis of differences in driver experience, operational requirements, and economic outcomes attributable to the three versions of the ICOA in use during the relevant period: ICOA v1.0 (original version, in use since 2018), ICOA v2.0 (revised version, effective August 2020), and ICOA v3.0 (revised version, effective January 2023), including detailed analysis of the impact of the mandatory arbitration clause and collective action waiver added in ICOA v3.0 on the composition, size, and characteristics of the proposed collective, taking into account that approximately 640 of the 1,187 drivers executed ICOA v3.0;

(d) Review and analysis of SLG's operational data, including RouteSync dispatch data, GPS telematics logs, pay records, driver delivery acceptance and refusal records, and subcontracting request and approval records, as further described in Section 5.1 of this Agreement;

(e) Preparation of a preliminary analysis report (the "Preliminary Analysis Report") summarizing CRA's initial statistical and economic findings, which shall be prepared for C&H's internal use in connection with litigation strategy and shall be treated as attorney work product; and

(f) Preparation of a sworn expert declaration by Dr. Priya Ramanathan (the "Expert Declaration") in support of SLG's opposition to plaintiff's motion for conditional certification, setting forth Dr. Ramanathan's expert opinions, the bases therefor, and the data and methodologies upon which such opinions rely.

1.3 Scope of Services — Merits Phase

Following the Court's ruling on conditional certification, and subject to C&H's further direction, CRA shall perform the following services during the merits phase of the Litigation:

(a) Expanded statistical and economic analysis for the merits phase, including a comprehensive analysis of the FLSA economic reality test factors as applied to the driver population, with attention to the degree of individual variation in each factor across the collective;

(b) Analysis of individual versus collective characteristics of the drivers relevant to damages calculations, including per-driver weekly unpaid overtime calculations under plaintiff's damages theory. As alleged by plaintiff, the claimed per-driver weekly overtime shortfall is approximately $193.50 per week, based on an average of 18 overtime hours per week at the differential between plaintiff's alleged regular rate of $32.25 per hour and the applicable FLSA overtime rate implied by plaintiff's theory of $21.50 per hour. CRA shall evaluate the factual and statistical validity of plaintiff's damages assumptions and methodology;

(c) Damages modeling and rebuttal analysis addressing plaintiff's estimated collective-wide damages exposure, which plaintiff has calculated at approximately $73,958,409.00 (including liquidated damages) for the full proposed collective of 1,187 drivers, and approximately $34,100,000.00 for a reduced collective of approximately 547 drivers (reflecting the exclusion of the approximately 640 drivers who executed ICOA v3.0 containing the collective action waiver, subject to the Court's ruling on enforceability);

(d) Preparation of a full expert report compliant with Federal Rule of Civil Procedure 26(a)(2)(B) (the "Expert Report"), setting forth Dr. Ramanathan's expert opinions, a complete statement of the bases and reasons for such opinions, the data and other information considered, any exhibits to be used in support of the opinions, Dr. Ramanathan's qualifications and publications, a list of all cases in which Dr. Ramanathan has testified as an expert at trial or by deposition within the preceding four years, and a statement of the compensation to be paid for the study and testimony in this case; and

(e) Testimony at deposition and trial, as required and directed by C&H, including preparation for such testimony as reasonably necessary.

1.4 Limitations on Scope

CRA shall perform all services under this Agreement solely at the direction of and under the supervision of C&H. CRA shall not communicate directly with SLG personnel, opposing counsel (Hartwell & Brashear PLLC), the Court, or any other party or third party involved in the Litigation without C&H's prior written authorization. All communications between CRA and SLG shall be coordinated through C&H. CRA's engagement under this Agreement is strictly litigation-related and limited to the services described herein. CRA is not being retained to provide general business consulting, operational advisory, or other non-litigation services to SLG, and nothing in this Agreement shall be construed to create any such engagement.

SECTION 2: LEAD CONSULTANT AND STAFFING

2.1 Lead Consultant

Dr. Priya Ramanathan shall serve as the Lead Consultant for the engagement and shall be expected to serve as the testifying expert witness in the Litigation if expert testimony is required by C&H. Dr. Ramanathan shall have personal responsibility for the direction, methodology, and conclusions of all analyses performed by CRA in connection with the engagement and shall personally supervise the preparation of all deliverables. A true and correct copy of Dr. Ramanathan's curriculum vitae is attached hereto as Exhibit A and incorporated herein by reference.

2.2 Associate Consultants

CRA may staff associate-level analysts and consultants on the engagement as reasonably necessary to support the work of the Lead Consultant, provided that CRA shall obtain C&H's prior written approval before assigning any such individual to the matter. CRA shall identify all proposed associate consultants to C&H in writing prior to such individuals commencing any work on the engagement, and such identification shall include each proposed associate consultant's name, qualifications, and proposed role. C&H shall have the right to disapprove any proposed associate consultant for any reason, including but not limited to potential conflicts of interest, and CRA shall promptly replace any disapproved individual with a suitable alternative, subject to C&H's approval.

2.3 Supervision. All work performed by associate consultants assigned to the engagement shall be performed under the direct supervision of Dr. Ramanathan. Dr. Ramanathan shall review and approve all analyses, memoranda, reports, and other work product prepared by associate consultants before such materials are submitted to C&H or otherwise used in connection with the Litigation. CRA shall ensure that all associate consultants assigned to the engagement are bound by confidentiality obligations at least as protective as those set forth in Section 4 of this Agreement.

SECTION 3: FEES AND BILLING

3.1 Hourly Rates

CRA shall be compensated for services performed under this Agreement at the following hourly rates:

The foregoing rates are effective as of the Effective Date of this Agreement and shall remain fixed throughout the conditional certification phase of the Litigation. Rates applicable to the merits phase of the Litigation may be adjusted by mutual written agreement of the Parties, provided that any such adjustment shall be documented in a written amendment to this Agreement or the Fee Schedule attached hereto as Exhibit B. Time shall be recorded in increments of one-tenth (0.1) of an hour.

3.2 Budget Parameters

The Parties have agreed upon the following budget parameters for the engagement:

(a) Conditional Certification Phase Budget: The total budget for CRA's services during the conditional certification phase of the Litigation shall be One Hundred Seventy-Five Thousand Dollars ($175,000.00) in fees. Of this amount, Ninety Thousand Dollars ($90,000.00) is allocated as the expert preliminary analysis component within C&H's overall Phase 1 billing cap of Four Hundred Seventy-Five Thousand Dollars ($475,000.00), which Phase 1 billing cap comprises Three Hundred Eighty-Five Thousand Dollars ($385,000.00) in C&H legal fees and Ninety Thousand Dollars ($90,000.00) in expert preliminary analysis fees. The remaining Eighty-Five Thousand Dollars ($85,000.00) of the conditional certification phase expert budget shall cover additional analysis work, preparation of the Expert Declaration, and all related work through the Court's ruling on conditional certification.

(b) Total Estimated Budget Through Trial: The total estimated budget for CRA's services from the Effective Date through the conclusion of trial is Four Hundred Fifty Thousand Dollars ($450,000.00) in fees. This amount is inclusive of the conditional certification phase budget described in subsection (a) above and covers expanded merits-phase analysis, preparation of the Rule 26(a)(2)(B) Expert Report, deposition preparation and testimony, and trial preparation and testimony. This estimate is based on the Parties' current understanding of the scope of the engagement and may be revised by mutual written agreement as the Litigation progresses.

The budget parameters set forth in this Section 3.2 represent estimates of anticipated fees based on the Parties' current understanding of the scope of services required. Actual fees will depend on the scope and complexity of the work ultimately required and may vary from these estimates.

3.3 Budget Overages

CRA shall monitor its fees and hours on an ongoing basis and shall notify C&H in writing promptly upon determining that fees incurred or reasonably anticipated to be incurred will exceed eighty percent (80%) of the applicable phase budget set forth in Section 3.2. Such notice shall include a summary of work performed to date, fees incurred, and an estimate of additional fees anticipated to complete the remaining scope of work for the applicable phase. CRA shall not exceed any phase budget without C&H's prior written approval. C&H shall endeavor to provide CRA with reasonable notice of any modifications to the budget or scope of services that may affect the budget parameters.

3.4 Expenses. CRA shall be reimbursed for reasonable, documented out-of-pocket expenses actually incurred in connection with the performance of services under this Agreement. Reimbursable expenses include, but are not limited to, travel expenses (airfare, ground transportation, lodging, and meals), data acquisition costs, specialized software or computing costs directly attributable to the engagement, printing and reproduction costs, and courier or delivery charges. Travel expenses shall be pre-approved by C&H for any single expenditure exceeding One Thousand Dollars ($1,000.00). All travel shall be at coach-class rates unless otherwise approved in writing by C&H. Expenses are not included in the hourly rate budgets set forth in Section 3.2 and shall be billed separately from professional fees.

3.5 Invoicing and Payment

CRA shall submit monthly invoices to C&H, itemizing hours worked by each timekeeper on a daily basis, a reasonably detailed description of the services performed, and all expenses incurred during the applicable billing period. Invoices shall be submitted within fifteen (15) calendar days following the end of each calendar month. C&H shall pay CRA's invoices within thirty (30) calendar days of receipt of a properly submitted invoice. Any dispute regarding the amount of an invoice shall be communicated by C&H to CRA in writing within fifteen (15) calendar days of receipt, and the undisputed portion of such invoice shall be paid in accordance with this Section 3.5. Invoices shall be directed to:

Renata Vasquez, Billing Partner Calderwood & Harkness LLP 2200 Ross Avenue, Suite 3600 Dallas, Texas 75201

Email: rvasquez@calderwoodharkness.com

3.6 Payment Responsibility

C&H, on behalf of SLG, is responsible for the payment of all fees and expenses incurred by CRA under this Agreement. CRA acknowledges that SLG is the ultimate payor for all amounts due under this Agreement and that C&H acts as SLG's authorized agent for purposes of this engagement, including with respect to the authorization and approval of fees, expenses, and budget matters. CRA shall have no direct billing relationship with SLG unless otherwise agreed in writing by all Parties.

SECTION 4: CONFIDENTIALITY

4.1 Confidential Information Defined

For purposes of this Agreement, "Confidential Information" means all information, documents, data, materials, communications, analyses, and work product provided by C&H or SLG to CRA in connection with the Litigation, or developed, prepared, or generated by CRA in the course of performing services under this Agreement, regardless of the form or medium in which such information is communicated or maintained (including written, oral, electronic, and visual forms). Confidential Information includes, without limitation, the following:

(a) RouteSync dispatch data, GPS telematics logs, and delivery route information;

(b) Driver pay records, including per-delivery payments, weekly and monthly compensation summaries, and any related accounting or payroll data;

(d) Driver personnel files, onboarding records, and performance records;

(e) Driver delivery acceptance and refusal records, subcontracting request and approval records, and multi-platform engagement data;

(f) SLG financial information, including but not limited to SLG's fiscal year 2024 revenue of approximately $312.7 million and EBITDA of approximately $28.4 million, and any other financial statements, projections, or business data provided in connection with the engagement;

(g) All attorney-client privileged communications between C&H and SLG, and between C&H and CRA, to the extent shared with CRA in connection with the engagement;

(h) All attorney work product prepared by C&H or at C&H's direction, including litigation strategies, legal analyses, case assessments, and settlement evaluations; and

(i) All draft reports, preliminary analyses, internal memoranda, working papers, and communications prepared by CRA at C&H's direction in anticipation of litigation or for the purpose of providing legal advice to SLG.

4.2 Obligations. CRA shall maintain all Confidential Information in strict confidence and shall not disclose, disseminate, publish, or otherwise make available any Confidential Information to any third party without the prior written consent of C&H. CRA shall limit access to Confidential Information to those CRA employees, consultants, and agents who have a demonstrated need to know such information for the purpose of performing services under this Agreement, and CRA shall ensure that all such individuals are bound by written confidentiality obligations at least as protective as those contained in this Section 4. CRA shall implement and maintain reasonable administrative, technical, and physical security measures to protect Confidential Information from unauthorized access, use, disclosure, alteration, or destruction, consistent with industry standards for the protection of sensitive litigation materials.

4.3 Privilege and Work Product Protection

CRA acknowledges and agrees that its work under this Agreement is being performed at the direction of C&H, in anticipation of litigation, and for the purpose of assisting C&H in providing legal advice to SLG. CRA's preliminary analyses, draft reports, internal communications with C&H, and all other materials prepared by CRA at C&H's direction that are not designated for disclosure to opposing parties or the Court are intended to be protected by the attorney-client privilege and/or the work product doctrine to the fullest extent permitted by applicable law. CRA shall not disclose any draft reports, preliminary analyses, internal memoranda, working papers, or communications with C&H unless and until C&H expressly authorizes such disclosure in writing. CRA acknowledges that CRA's final testifying expert reports and declarations, once designated by C&H for disclosure pursuant to applicable rules of civil procedure or court order, may be subject to discovery by opposing parties and are not covered by the privilege protections described in this Section 4.3.

4.4 Return or Destruction of Materials

Upon termination or conclusion of the engagement, or at any time upon C&H's written request, CRA shall, at C&H's direction, either: (a) promptly return to C&H all Confidential Information in CRA's possession, custody, or control, including all copies, summaries, extracts, and derivative works thereof, in whatever form or medium; or (b) destroy all such Confidential Information and certify such destruction in writing to C&H within fifteen (15) calendar days of the date of destruction. Notwithstanding the foregoing, CRA may retain one archival copy of Confidential Information to the extent required by applicable law, regulation, or professional standards, provided that such retained copy shall remain subject to the confidentiality obligations set forth in this Section 4 for so long as it is maintained.

SECTION 5: DATA ACCESS AND HANDLING

5.1 Data to Be Provided

C&H shall arrange for CRA to receive access to the following data and documents from SLG in connection with CRA's performance of services under this Agreement:

(a) RouteSync dispatch records for all delivery drivers across all fourteen (14) SLG distribution hubs during the relevant period (April 30, 2022 through the present), including delivery assignment data, delivery completion data, and time-stamped dispatch records;

(b) GPS telematics data for all delivery drivers, including real-time location data, route adherence data, and stop-time records;

(c) Pay records for all 1,187 unique delivery drivers who performed services for SLG under an ICOA during the relevant period, including per-delivery payment amounts, weekly and monthly compensation summaries, and any adjustment or bonus payments;

(d) ICOA execution records, identifying which version of the ICOA (v1.0, v2.0, or v3.0) each driver executed, the date of execution, and the distribution hub to which each driver was assigned;

(e) Driver delivery acceptance and refusal logs, documenting each driver's delivery acceptance rate relative to the 85% minimum acceptance rate specified in the ICOAs, including any notices of non-compliance or warnings issued to drivers;

(f) Subcontracting request and approval records, documenting instances in which drivers requested authorization to engage subcontractors to perform deliveries and the disposition of such requests;

(g) Multi-platform engagement data, to the extent available in SLG's records, documenting the extent to which drivers simultaneously performed delivery services for other companies or platforms during the relevant period; and

(h) Hub-level operational policies and procedures for all fourteen (14) SLG distribution hubs, including any hub-specific supplements or modifications to the standard ICOA terms, dispatch protocols, or performance standards.

C&H shall use reasonable efforts to provide or arrange access to the foregoing data in a timely manner consistent with the deliverable deadlines set forth in Section 6 of this Agreement. CRA shall promptly notify C&H of any data gaps, quality issues, or additional data needs identified during the course of the engagement.

5.2 Data Security

CRA shall store all electronically transmitted data and Confidential Information received in connection with the engagement on encrypted, password-protected systems that meet or exceed industry-standard security protocols. CRA shall not transmit Confidential Information via unsecured email, unsecured file transfer services, or any other unsecured communication channel. CRA shall use secure file transfer protocols (SFTP) or equally secure methods for the transmission of electronic data between CRA and C&H. CRA shall comply with any electronically stored information ("ESI") protocols, protective orders, or data handling requirements established by the Court or agreed upon by the parties in the Litigation. CRA shall promptly notify C&H of any actual or suspected security breach involving Confidential Information.

SECTION 6: DELIVERABLES AND TIMELINE

6.1 Conditional Certification Phase Deliverables

CRA shall prepare and deliver the following work product during the conditional certification phase of the Litigation:

(a) Preliminary Analysis Report: An internal memorandum addressed to C&H summarizing CRA's initial statistical and economic findings regarding the similarly situated analysis, including preliminary observations regarding variance in key metrics across the driver population and across ICOA versions. The Preliminary Analysis Report shall be prepared for C&H's internal use in developing litigation strategy and shall be treated as attorney work product. Due Date: June 20, 2025.

(b) Expert Declaration: A final sworn declaration of Dr. Priya Ramanathan, executed under penalty of perjury, setting forth Dr. Ramanathan's expert opinions, the bases and reasons therefor, and the data, methodologies, and analyses upon which such opinions rely, in support of SLG's opposition to plaintiff's motion for conditional certification of the proposed FLSA collective. The Expert Declaration shall be delivered to C&H in final form sufficiently in advance of the filing deadline to allow C&H adequate time for review and incorporation into the opposition brief. Due Date: July 25, 2025 (in advance of the August 13, 2025 deadline for Defendant's response to plaintiff's motion for conditional certification).

6.2 Merits Phase Deliverables

Subject to C&H's further direction and the Court's scheduling order, CRA shall prepare and deliver the following work product during the merits phase of the Litigation:

(a) Expert Report: A full expert report compliant with the requirements of Federal Rule of Civil Procedure 26(a)(2)(B), including all required disclosures. The Expert Report shall set forth Dr. Ramanathan's complete expert opinions on the merits issues, including the economic reality test analysis and damages rebuttal, together with a complete statement of the bases and reasons for each opinion, the data and other information considered, all exhibits to be used in support of the opinions, Dr. Ramanathan's qualifications, a list of all cases in which Dr. Ramanathan has testified as an expert at trial or by deposition within the preceding four years, and a statement of the compensation to be paid for the study and testimony in this case. Due Date: To be determined by the Court's scheduling order; the current discovery cutoff is March 15, 2026, and the expert report deadline will be established in due course.

(b) Deposition Preparation: CRA shall make Dr. Ramanathan available for deposition preparation sessions with C&H and for expert deposition, as scheduled by the parties in accordance with the Court's scheduling order and applicable rules.

(c) Trial Preparation and Testimony: CRA shall make Dr. Ramanathan available for trial preparation sessions with C&H and for live testimony at trial. Trial is currently set for September 14, 2026, before the Honorable Rebecca Chen.

6.3 Additional Deliverables

CRA shall prepare and deliver such other analyses, memoranda, presentations, or work product as C&H may reasonably request in connection with the Litigation, subject to the budget parameters set forth in Section 3.2 and CRA's right to notification and approval for budget overages as set forth in Section 3.3.

SECTION 7: INDEPENDENCE AND OBJECTIVITY

7.1 Expert Independence

CRA and Dr. Ramanathan shall conduct all analyses under this Agreement independently and shall render opinions based solely upon their professional judgment, recognized methodologies in labor economics and applied statistics, and the data and information available to them. C&H acknowledges that CRA's conclusions and opinions must be scientifically and methodologically supportable and that CRA cannot and does not guarantee any particular outcome, conclusion, or opinion. C&H further acknowledges that Dr. Ramanathan's opinions, once formed, must be stated honestly and completely regardless of whether such opinions are favorable or unfavorable to SLG's position in the Litigation. CRA shall promptly notify C&H if, in the course of its analysis, CRA reaches any conclusion that may be adverse to SLG's position, so that C&H may evaluate the implications and provide further direction regarding the scope and use of CRA's work product.

7.2 No Conflicts

CRA represents and warrants that, as of the Effective Date of this Agreement, it has conducted a reasonable conflicts check and has identified no existing engagement, relationship, financial interest, or other circumstance that would create a conflict of interest with respect to the services to be performed under this Agreement. Specifically, CRA represents that neither CRA nor any of its principals, employees, or consultants has previously been engaged by or on behalf of Marcus Delano, Hartwell & Brashear PLLC, or any other party adverse to SLG in the Litigation, or has any personal, financial, or professional relationship with any such party that could reasonably be expected to compromise CRA's independence or objectivity. CRA shall promptly notify C&H in writing if any actual or potential conflict of interest arises during the course of the engagement, and the Parties shall confer in good faith regarding the appropriate course of action to address any such conflict.

SECTION 8: TERM AND TERMINATION

8.1 Term. This Agreement shall be effective as of the Effective Date and shall continue in full force and effect until the earliest of: (a) the completion of all services described herein and the payment of all amounts due to CRA; (b) the final resolution of the Litigation, whether by judgment, settlement, dismissal, or otherwise; or (c) termination by either Party pursuant to Section 8.2 of this Agreement.

8.2 Termination. Either Party may terminate this Agreement at any time, with or without cause, upon thirty (30) calendar days' prior written notice to the other Party, delivered in accordance with the notice provisions of Section 13.4 of this Agreement. In the event of termination by either Party, CRA shall be entitled to compensation for all services rendered and all expenses properly incurred through the effective date of termination, subject to the invoicing and payment provisions of Section 3.5. Upon termination, CRA shall promptly deliver to C&H all completed and partially completed work product in CRA's possession and shall comply with the confidentiality, data return, and data destruction provisions set forth in Sections 4 and 5 of this Agreement. C&H shall use reasonable efforts to provide CRA with sufficient notice of termination to allow for an orderly transition of the engagement.

8.3 Survival. The following provisions of this Agreement shall survive the termination or expiration of this Agreement and shall continue in full force and effect indefinitely or for the period specified therein, as applicable: Section 4 (Confidentiality), Section 5.2 (Data Security), Section 9 (Indemnification), and Section 10 (Limitation of Liability). The survival of such provisions shall not be affected by the reason for termination or the Party that initiated the termination.

SECTION 9: INDEMNIFICATION

9.1 Indemnification by C&H / SLG

C&H, on behalf of SLG, shall indemnify, defend, and hold harmless CRA and its officers, members, managers, employees, agents, and consultants (each, a "CRA Indemnified Party") from and against any and all third-party claims, demands, actions, suits, losses, damages, liabilities, costs, and expenses (including reasonable attorneys' fees and court costs) arising out of or relating to CRA's performance of services under this Agreement or CRA's use of data or information provided by C&H or SLG, except to the extent that such claims, losses, or liabilities are caused by or result from CRA's gross negligence or willful misconduct in the performance of services under this Agreement.

9.2 Indemnification by CRA

CRA shall indemnify, defend, and hold harmless C&H and SLG, and their respective partners, officers, directors, employees, agents, and representatives (each, an "C&H/SLG Indemnified Party"), from and against any and all claims, demands, actions, suits, losses, damages, liabilities, costs, and expenses (including reasonable attorneys' fees and court costs) arising out of or relating to CRA's gross negligence or willful misconduct in the performance of services under this Agreement, including but not limited to any breach by CRA of its confidentiality or data security obligations under Sections 4 and 5 of this Agreement that is attributable to CRA's gross negligence or willful misconduct.

SECTION 10: LIMITATION OF LIABILITY

CRA's aggregate liability to C&H and SLG under this Agreement, whether arising in contract, tort, strict liability, or otherwise, shall not exceed the total amount of fees actually paid to CRA under this Agreement as of the date on which any claim for liability is asserted. In no event shall either Party be liable to the other Party for any indirect, incidental, consequential, special, exemplary, or punitive damages of any kind, including but not limited to lost profits, loss of business opportunity, or loss of data, arising out of or in connection with this Agreement or the services performed hereunder, regardless of whether such damages are foreseeable and regardless of whether such Party has been advised of the possibility of such damages. The limitations set forth in this Section 10 shall not apply to a Party's indemnification obligations under Section 9 or to any liability arising from a Party's willful misconduct or intentional breach of this Agreement.

SECTION 11: REPRESENTATIONS AND WARRANTIES

11.1 CRA Representations

CRA represents and warrants to C&H and SLG as follows:

(a) CRA is a limited liability company duly organized, validly existing, and in good standing under the laws of the Commonwealth of Virginia, and has all requisite power and authority to enter into this Agreement and to perform its obligations hereunder;

(b) Dr. Priya Ramanathan is a qualified expert in labor economics and statistical analysis, holds a Ph.D. in Economics, and has extensive experience providing expert economic and statistical analysis in FLSA collective actions, worker misclassification litigation, and related employment matters. Dr. Ramanathan has been qualified as an expert witness and has testified in federal and state courts in multiple jurisdictions;

(c) CRA has the capacity, personnel, and resources to perform the services described in this Agreement within the timelines specified herein and in accordance with the professional standards applicable to expert economic and statistical analysis in federal litigation; and

(d) The execution, delivery, and performance of this Agreement by CRA do not and will not conflict with or violate any agreement, obligation, or order to which CRA is a party or by which CRA is bound.

11.2 C&H Representations

C&H represents and warrants to CRA as follows:

(a) C&H is a limited liability partnership duly organized and existing under the laws of the State of New York and is authorized to practice law in the State of Texas;

(b) C&H is duly authorized to enter into this Agreement on behalf of SLG and to retain expert consultants in connection with the defense of the Litigation;

(c) C&H has obtained SLG's authorization for the engagement of CRA on the terms described herein, including the scope of services and the budget parameters set forth in Section 3; and

(d) C&H shall use reasonable efforts to provide CRA with timely access to the data, documents, and information necessary for CRA to perform its obligations under this Agreement.

SECTION 12: GOVERNING LAW AND DISPUTE RESOLUTION

This Agreement shall be governed by and construed in accordance with the laws of the State of Texas, without regard to the conflict of laws principles thereof. Any dispute, controversy, or claim arising out of or relating to this Agreement, or the breach, termination, or validity thereof, that cannot be resolved by good-faith negotiation between the Parties within thirty (30) calendar days after written notice of the dispute is given by one Party to the other, shall be finally resolved by binding arbitration administered in Dallas, Texas, under the Commercial Arbitration Rules of the American Arbitration Association then in effect. The arbitration shall be conducted by a single arbitrator mutually selected by the Parties. The arbitrator's decision shall be final and binding upon the Parties and may be entered as a judgment in any court of competent jurisdiction. Each Party shall bear its own costs and attorneys' fees in connection with any arbitration, unless the arbitrator determines that the award of costs and fees to the prevailing party is appropriate under the circumstances.

SECTION 13: MISCELLANEOUS

13.1 Entire Agreement

This Agreement, together with Exhibit A (Curriculum Vitae of Dr. Priya Ramanathan), Exhibit B (Fee Schedule), and Exhibit C (Matter Information), which are attached hereto and incorporated herein by reference, constitutes the entire agreement between the Parties with respect to the subject matter hereof and supersedes all prior and contemporaneous discussions, negotiations, understandings, representations, and agreements, whether oral or written, between the Parties relating to the subject matter of this Agreement.

13.2 Amendments. This Agreement may not be amended, modified, or supplemented except by a written instrument duly executed by authorized representatives of both Parties. No oral modification, amendment, or waiver of any provision of this Agreement shall be effective.

13.3 Assignment. Neither Party may assign, transfer, or delegate this Agreement or any of its rights or obligations hereunder without the prior written consent of the other Party, and any attempted assignment without such consent shall be null and void. Notwithstanding the foregoing, C&H may assign this Agreement to a successor law firm representing SLG in the Litigation, provided that C&H gives CRA prompt written notice of such assignment.

13.4 Notices. All notices, requests, demands, consents, and other communications required or permitted under this Agreement shall be in writing and shall be deemed duly given when: (a) delivered personally; (b) sent by certified or registered United States mail, return receipt requested, postage prepaid; (c) sent by a nationally recognized overnight courier service; or (d) transmitted by email with confirmation of receipt, addressed as follows:

If to C&H:

Bernard Crawford, Partner Calderwood & Harkness LLP 2200 Ross Avenue, Suite 3600 Dallas, Texas 75201

Email: bcrawford@calderwoodharkness.com

If to CRA:

Dr. Priya Ramanathan, Managing Principal Corbin Risk Advisors LLC 1901 N. Moore Street, Suite 1020 Arlington, Virginia 22209

Email: pramanathan@corbinrisk.com

Either Party may change its address for purposes of this Section 13.4 by giving written notice thereof to the other Party in accordance with this Section.

13.5 Counterparts. This Agreement may be executed in two or more counterparts, each of which shall be deemed an original and all of which together shall constitute one and the same instrument. Execution and delivery of this Agreement by electronic signature or by facsimile transmission of a signed counterpart shall be deemed to be, and shall have the same force and effect as, execution and delivery of an original signed counterpart.

13.6 Waiver. The failure of either Party to enforce any provision of this Agreement at any time or for any period of time shall not constitute a waiver of such provision or of the right of such Party to enforce such provision or any other provision of this Agreement at any future time. No waiver of any provision of this Agreement shall be effective unless made in writing and signed by the waiving Party.

IN WITNESS WHEREOF, the Parties have executed this Expert Retention Agreement as of the date first written above.

CALDERWOOD & HARKNESS LLP

By: ________

Name: Bernard Crawford

Title: Partner, Labor & Employment Practice Group

Date: May 8, 2025

CORBIN RISK ADVISORS LLC

By: ________

Name: Dr. Priya Ramanathan

Title: Managing Principal

Date: May 8, 2025

EXHIBIT A

CURRICULUM VITAE OF DR. PRIYA RAMANATHAN

DR. PRIYA RAMANATHAN

Managing Principal Corbin Risk Advisors LLC 1901 N. Moore Street, Suite 1020 Arlington, Virginia 22209

EDUCATION. Ph.D., Economics — University of Michigan, Ann Arbor, MI (2007) Dissertation: Structural Models of Labor Market Segmentation and Misclassification in the U.S. Transportation Sector

M.A., Economics — University of Michigan, Ann Arbor, MI (2004)

B.A., Mathematics and Economics (summa cum laude) — University of Virginia, Charlottesville, VA (2002)

PROFESSIONAL EXPERIENCE. Managing Principal, Corbin Risk Advisors LLC, Arlington, VA (2016–Present)

Leads the firm's labor economics and employment litigation practice. Provides expert economic and statistical analysis in connection with FLSA collective actions, state wage-and-hour class actions, worker misclassification disputes, Title VII statistical analyses, and other employment-related litigation. Directs a team of associate consultants and analysts. Serves as testifying expert in federal and state courts nationwide.

Senior Economist, Bureau of Labor Statistics, U.S. Department of Labor, Washington, DC (2011–2016)

Led research projects on independent contractor classification trends and labor market dynamics in the logistics and transportation sectors. Developed statistical models for analyzing contingent workforce data and contributed to the redesign of the Current Population Survey Contingent Worker Supplement.

Assistant Professor, Department of Economics, George Mason University, Fairfax, VA (2007–2011)

Taught graduate and undergraduate courses in labor economics, econometrics, and applied statistics. Conducted peer-reviewed research on worker classification, wage determination, and overtime compensation in the gig economy and logistics industry.

EXPERT TESTIMONY EXPERIENCE

Dr. Ramanathan has been retained as a consulting or testifying expert in more than forty (40) matters involving FLSA collective actions, state wage-and-hour class actions, and worker misclassification litigation. Dr. Ramanathan has been qualified as an expert witness and has testified at trial or by deposition in the following representative matters, among others:

• Reynolds et al. v. [National Parcel Delivery Company], U.S. District Court for the Eastern District of Pennsylvania (FLSA collective action, driver misclassification; testified at trial, 2024)

• Carter v. [Regional Logistics Provider], U.S. District Court for the Middle District of Tennessee (FLSA collective action, conditional certification; deposition testimony, 2023)

• [Multi-Plaintiff Class] v. [Technology Platform Company], Superior Court of California, County of Los Angeles (state wage-and-hour class action, gig worker classification; deposition testimony, 2022)

• [Named Plaintiff] v. [Interstate Freight Carrier], U.S. District Court for the Northern District of Illinois (FLSA collective action, overtime and misclassification; testified at trial, 2021)

• [Named Plaintiff] v. [Healthcare Staffing Agency], U.S. District Court for the Southern District of Texas (FLSA collective action, nurse contractor classification; deposition testimony, 2020)

Note: Client names have been replaced with generic descriptions in certain entries to maintain client confidentiality in accordance with applicable ethical obligations and prior engagement agreements.

Dr. Ramanathan has provided expert testimony at trial in seven (7) matters and by deposition in twenty-six (26) matters within the preceding four years.

SELECTED PUBLICATIONS.

1. Ramanathan, P. & Liu, J., "Statistical Approaches to the Similarly Situated Inquiry in FLSA Collective Actions," Journal of Labor Economics, Vol. 41, No. 3 (2023), pp. 487–522.

2. Ramanathan, P., "Economic Reality and the Independent Contractor: A Quantitative Framework for Multifactor Classification Analysis," Industrial & Labor Relations Review, Vol. 75, No. 2 (2022), pp. 312–349.

3. Ramanathan, P. & Okafor, C., "Variance and Commonality: Measuring Heterogeneity in Proposed FLSA Collectives," Stanford Law & Policy Review, Vol. 32, No. 1 (2021), pp. 89–128.

4. Ramanathan, P., "Overtime Compensation and the Gig Economy: An Empirical Analysis of Misclassification in Last-Mile Delivery," Monthly Labor Review, U.S. Bureau of Labor Statistics (2019), pp. 1–24.

5. Ramanathan, P. & Bergstrom, H., "Contingent Workers and Wage Dynamics in the U.S. Logistics Sector," American Economic Review: Papers & Proceedings, Vol. 108 (2018), pp. 201–205.

PROFESSIONAL AFFILIATIONS.

• American Economic Association (Member)

• Society of Labor Economists (Member)

• National Association of Forensic Economics (Fellow)

• American Statistical Association, Section on Statistics in Business and Economic Statistics (Member)

PROFESSIONAL CERTIFICATIONS AND HONORS

• Certified in Quantitative Finance (CQF), 2014

EXPERT RETENTION AGREEMENT
Between
Calderwood & Harkness LLP (on behalf of Stonefield Logistics Group Inc.)
and
Corbin Risk Advisors LLC
Dated as of May 8, 2025
C&H Matter No. 1012-00004
Delano v. Stonefield Logistics Group Inc. Case No. 3:25-cv-01847-RBC United States District Court for the Northern District of Texas, Dallas Division
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EXPERT RETENTION AGREEMENT
This Expert Retention Agreement (this "Agreement") is made and entered into as of May 8, 2025 (the "Effective Date"), by and between:
Calderwood & Harkness LLP, a limited liability partnership organized and existing under the laws of the State of New York, with offices at 2200 Ross Avenue, Suite 3600, Dallas, Texas 75201 ("Retaining Counsel" or "C&H"), acting on behalf of its client Stonefield Logistics Group Inc., a corporation organized and existing under the laws of the State of Delaware, with its principal place of business and corporate headquarters at 4200 Commerce Gateway Blvd., Suite 800, Irving, Texas 75039 (the "Client" or "SLG");
and
Corbin Risk Advisors LLC, a limited liability company organized and existing under the laws of the Commonwealth of Virginia, with its principal offices at 1901 N. Moore Street, Suite 1020, Arlington, Virginia 22209 (the "Consultant" or "CRA").
C&H and CRA are each referred to herein individually as a "Party" and collectively as the "Parties."
RECITALS.  WHEREAS:
A. C&H represents SLG in the defense of a collective action filed under the Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq. ("FLSA"), and the Texas Payday Law, Tex. Lab. Code Ann. §§ 61.001 et seq., captioned Delano v. Stonefield Logistics Group Inc., Case No. 3:25-cv-01847-RBC, pending before the Honorable Rebecca Chen, United States District Judge, in the United States District Court for the Northern District of Texas, Dallas Division (the "Litigation");
B. The named plaintiff in the Litigation, Marcus Delano, a former delivery driver who performed services for SLG, alleges that SLG misclassified approximately 1,187 delivery drivers as independent contractors rather than employees, thereby depriving such drivers of overtime compensation in violation of the FLSA and applicable Texas law. Plaintiff seeks conditional certification of a collective comprising all individuals who performed delivery driving services for SLG pursuant to an Independent Contractor Operating Agreement ("ICOA") during the period from April 30, 2022 through the date of final judgment in the Litigation;
C. C&H desires to retain CRA to provide expert economic and statistical analysis services in support of SLG's defense of the Litigation, including but not limited to analysis relevant to the conditional certification phase and the merits phase of the Litigation, and CRA desires to provide such services on the terms and conditions set forth herein;
D. CRA, through its lead consultant Dr. Priya Ramanathan, a labor economist with extensive experience in FLSA collective action and worker classification matters, possesses the requisite expertise, qualifications, and resources to provide the economic and statistical analysis services required in connection with the Litigation; and
E. C&H and CRA desire to set forth the terms and conditions governing CRA's engagement, including the scope of services, compensation, confidentiality obligations, and related matters.
NOW, THEREFORE, in consideration of the mutual covenants and agreements set forth herein, and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties agree as follows:
SECTION 1: ENGAGEMENT AND SCOPE OF SERVICES
1.1 Retention.  C&H hereby retains CRA, and CRA hereby accepts the retention, to serve as expert consultant and, as may be required by C&H in connection with the Litigation, as a testifying expert witness, on the terms and subject to the conditions set forth in this Agreement. CRA's lead consultant for this engagement shall be Dr. Priya Ramanathan (the "Lead Consultant"). Dr. Ramanathan shall have primary responsibility for all substantive work performed by CRA under this Agreement and shall serve as the principal point of contact between CRA and C&H. CRA may assign additional associate-level consultants and analysts to the engagement as reasonably necessary to fulfill its obligations hereunder, provided that any such assignment shall be subject to C&H's prior written approval, which shall not be unreasonably withheld.
1.2 Scope of Services — Conditional Certification Phase
During the conditional certification phase of the Litigation, CRA shall perform the following services at C&H's direction:
(a) Statistical and economic analysis of whether SLG's approximately 1,187 delivery drivers who executed ICOAs during the relevant period (April 30, 2022 through the present) are "similarly situated" for purposes of FLSA conditional certification under 29 U.S.C. § 216(b), including analysis of the degree of individualized variation among the driver population;
(b) Analysis of variance in key operational and economic metrics across the driver population, including but not limited to: (i) weekly hours worked; (ii) gross pay and per-delivery compensation; (iii) delivery acceptance rates, measured against the 85% minimum acceptance rate per rolling 30-day period specified in the ICOAs; (iv) route deviation frequency; and (v) multi-platform engagement (i.e., the extent to which drivers simultaneously performed delivery services for other companies or platforms during the relevant period), with such analyses conducted across and within SLG's fourteen (14) distribution hubs located in Texas, Oklahoma, Louisiana, and Arkansas;
(c) Analysis of differences in driver experience, operational requirements, and economic outcomes attributable to the three versions of the ICOA in use during the relevant period: ICOA v1.0 (original version, in use since 2018), ICOA v2.0 (revised version, effective August 2020), and ICOA v3.0 (revised version, effective January 2023), including detailed analysis of the impact of the mandatory arbitration clause and collective action waiver added in ICOA v3.0 on the composition, size, and characteristics of the proposed collective, taking into account that approximately 640 of the 1,187 drivers executed ICOA v3.0;
(d) Review and analysis of SLG's operational data, including RouteSync dispatch data, GPS telematics logs, pay records, driver delivery acceptance and refusal records, and subcontracting request and approval records, as further described in Section 5.1 of this Agreement;
(e) Preparation of a preliminary analysis report (the "Preliminary Analysis Report") summarizing CRA's initial statistical and economic findings, which shall be prepared for C&H's internal use in connection with litigation strategy and shall be treated as attorney work product; and
(f) Preparation of a sworn expert declaration by Dr. Priya Ramanathan (the "Expert Declaration") in support of SLG's opposition to plaintiff's motion for conditional certification, setting forth Dr. Ramanathan's expert opinions, the bases therefor, and the data and methodologies upon which such opinions rely.
1.3 Scope of Services — Merits Phase
Following the Court's ruling on conditional certification, and subject to C&H's further direction, CRA shall perform the following services during the merits phase of the Litigation:
(a) Expanded statistical and economic analysis for the merits phase, including a comprehensive analysis of the FLSA economic reality test factors as applied to the driver population, with attention to the degree of individual variation in each factor across the collective;
(b) Analysis of individual versus collective characteristics of the drivers relevant to damages calculations, including per-driver weekly unpaid overtime calculations under plaintiff's damages theory. As alleged by plaintiff, the claimed per-driver weekly overtime shortfall is approximately $193.50 per week, based on an average of 18 overtime hours per week at the differential between plaintiff's alleged regular rate of $32.25 per hour and the applicable FLSA overtime rate implied by plaintiff's theory of $21.50 per hour. CRA shall evaluate the factual and statistical validity of plaintiff's damages assumptions and methodology;
(c) Damages modeling and rebuttal analysis addressing plaintiff's estimated collective-wide damages exposure, which plaintiff has calculated at approximately $73,958,409.00 (including liquidated damages) for the full proposed collective of 1,187 drivers, and approximately $34,100,000.00 for a reduced collective of approximately 547 drivers (reflecting the exclusion of the approximately 640 drivers who executed ICOA v3.0 containing the collective action waiver, subject to the Court's ruling on enforceability);
(d) Preparation of a full expert report compliant with Federal Rule of Civil Procedure 26(a)(2)(B) (the "Expert Report"), setting forth Dr. Ramanathan's expert opinions, a complete statement of the bases and reasons for such opinions, the data and other information considered, any exhibits to be used in support of the opinions, Dr. Ramanathan's qualifications and publications, a list of all cases in which Dr. Ramanathan has testified as an expert at trial or by deposition within the preceding four years, and a statement of the compensation to be paid for the study and testimony in this case; and
(e) Testimony at deposition and trial, as required and directed by C&H, including preparation for such testimony as reasonably necessary.
1.4 Limitations on Scope
CRA shall perform all services under this Agreement solely at the direction of and under the supervision of C&H. CRA shall not communicate directly with SLG personnel, opposing counsel (Hartwell & Brashear PLLC), the Court, or any other party or third party involved in the Litigation without C&H's prior written authorization. All communications between CRA and SLG shall be coordinated through C&H. CRA's engagement under this Agreement is strictly litigation-related and limited to the services described herein. CRA is not being retained to provide general business consulting, operational advisory, or other non-litigation services to SLG, and nothing in this Agreement shall be construed to create any such engagement.
SECTION 2: LEAD CONSULTANT AND STAFFING
2.1 Lead Consultant
Dr. Priya Ramanathan shall serve as the Lead Consultant for the engagement and shall be expected to serve as the testifying expert witness in the Litigation if expert testimony is required by C&H. Dr. Ramanathan shall have personal responsibility for the direction, methodology, and conclusions of all analyses performed by CRA in connection with the engagement and shall personally supervise the preparation of all deliverables. A true and correct copy of Dr. Ramanathan's curriculum vitae is attached hereto as Exhibit A and incorporated herein by reference.
2.2 Associate Consultants
CRA may staff associate-level analysts and consultants on the engagement as reasonably necessary to support the work of the Lead Consultant, provided that CRA shall obtain C&H's prior written approval before assigning any such individual to the matter. CRA shall identify all proposed associate consultants to C&H in writing prior to such individuals commencing any work on the engagement, and such identification shall include each proposed associate consultant's name, qualifications, and proposed role. C&H shall have the right to disapprove any proposed associate consultant for any reason, including but not limited to potential conflicts of interest, and CRA shall promptly replace any disapproved individual with a suitable alternative, subject to C&H's approval.
2.3 Supervision.  All work performed by associate consultants assigned to the engagement shall be performed under the direct supervision of Dr. Ramanathan. Dr. Ramanathan shall review and approve all analyses, memoranda, reports, and other work product prepared by associate consultants before such materials are submitted to C&H or otherwise used in connection with the Litigation. CRA shall ensure that all associate consultants assigned to the engagement are bound by confidentiality obligations at least as protective as those set forth in Section 4 of this Agreement.
SECTION 3: FEES AND BILLING
3.1 Hourly Rates
CRA shall be compensated for services performed under this Agreement at the following hourly rates:
The foregoing rates are effective as of the Effective Date of this Agreement and shall remain fixed throughout the conditional certification phase of the Litigation. Rates applicable to the merits phase of the Litigation may be adjusted by mutual written agreement of the Parties, provided that any such adjustment shall be documented in a written amendment to this Agreement or the Fee Schedule attached hereto as Exhibit B. Time shall be recorded in increments of one-tenth (0.1) of an hour.
3.2 Budget Parameters
The Parties have agreed upon the following budget parameters for the engagement:
(a) Conditional Certification Phase Budget: The total budget for CRA's services during the conditional certification phase of the Litigation shall be One Hundred Seventy-Five Thousand Dollars ($175,000.00) in fees. Of this amount, Ninety Thousand Dollars ($90,000.00) is allocated as the expert preliminary analysis component within C&H's overall Phase 1 billing cap of Four Hundred Seventy-Five Thousand Dollars ($475,000.00), which Phase 1 billing cap comprises Three Hundred Eighty-Five Thousand Dollars ($385,000.00) in C&H legal fees and Ninety Thousand Dollars ($90,000.00) in expert preliminary analysis fees. The remaining Eighty-Five Thousand Dollars ($85,000.00) of the conditional certification phase expert budget shall cover additional analysis work, preparation of the Expert Declaration, and all related work through the Court's ruling on conditional certification.
(b) Total Estimated Budget Through Trial: The total estimated budget for CRA's services from the Effective Date through the conclusion of trial is Four Hundred Fifty Thousand Dollars ($450,000.00) in fees. This amount is inclusive of the conditional certification phase budget described in subsection (a) above and covers expanded merits-phase analysis, preparation of the Rule 26(a)(2)(B) Expert Report, deposition preparation and testimony, and trial preparation and testimony. This estimate is based on the Parties' current understanding of the scope of the engagement and may be revised by mutual written agreement as the Litigation progresses.
The budget parameters set forth in this Section 3.2 represent estimates of anticipated fees based on the Parties' current understanding of the scope of services required. Actual fees will depend on the scope and complexity of the work ultimately required and may vary from these estimates.
3.3 Budget Overages
CRA shall monitor its fees and hours on an ongoing basis and shall notify C&H in writing promptly upon determining that fees incurred or reasonably anticipated to be incurred will exceed eighty percent (80%) of the applicable phase budget set forth in Section 3.2. Such notice shall include a summary of work performed to date, fees incurred, and an estimate of additional fees anticipated to complete the remaining scope of work for the applicable phase. CRA shall not exceed any phase budget without C&H's prior written approval. C&H shall endeavor to provide CRA with reasonable notice of any modifications to the budget or scope of services that may affect the budget parameters.
3.4 Expenses.  CRA shall be reimbursed for reasonable, documented out-of-pocket expenses actually incurred in connection with the performance of services under this Agreement. Reimbursable expenses include, but are not limited to, travel expenses (airfare, ground transportation, lodging, and meals), data acquisition costs, specialized software or computing costs directly attributable to the engagement, printing and reproduction costs, and courier or delivery charges. Travel expenses shall be pre-approved by C&H for any single expenditure exceeding One Thousand Dollars ($1,000.00). All travel shall be at coach-class rates unless otherwise approved in writing by C&H. Expenses are not included in the hourly rate budgets set forth in Section 3.2 and shall be billed separately from professional fees.
3.5 Invoicing and Payment
CRA shall submit monthly invoices to C&H, itemizing hours worked by each timekeeper on a daily basis, a reasonably detailed description of the services performed, and all expenses incurred during the applicable billing period. Invoices shall be submitted within fifteen (15) calendar days following the end of each calendar month. C&H shall pay CRA's invoices within thirty (30) calendar days of receipt of a properly submitted invoice. Any dispute regarding the amount of an invoice shall be communicated by C&H to CRA in writing within fifteen (15) calendar days of receipt, and the undisputed portion of such invoice shall be paid in accordance with this Section 3.5. Invoices shall be directed to:
Renata Vasquez, Billing Partner Calderwood & Harkness LLP 2200 Ross Avenue, Suite 3600 Dallas, Texas 75201
Email: rvasquez@calderwoodharkness.com
3.6 Payment Responsibility
C&H, on behalf of SLG, is responsible for the payment of all fees and expenses incurred by CRA under this Agreement. CRA acknowledges that SLG is the ultimate payor for all amounts due under this Agreement and that C&H acts as SLG's authorized agent for purposes of this engagement, including with respect to the authorization and approval of fees, expenses, and budget matters. CRA shall have no direct billing relationship with SLG unless otherwise agreed in writing by all Parties.
SECTION 4: CONFIDENTIALITY
4.1 Confidential Information Defined
For purposes of this Agreement, "Confidential Information" means all information, documents, data, materials, communications, analyses, and work product provided by C&H or SLG to CRA in connection with the Litigation, or developed, prepared, or generated by CRA in the course of performing services under this Agreement, regardless of the form or medium in which such information is communicated or maintained (including written, oral, electronic, and visual forms). Confidential Information includes, without limitation, the following:
(a) RouteSync dispatch data, GPS telematics logs, and delivery route information;
(b) Driver pay records, including per-delivery payments, weekly and monthly compensation summaries, and any related accounting or payroll data;
(c) Independent Contractor Operating Agreements (ICOAs) in all versions (v1.0, v2.0, and v3.0);
(d) Driver personnel files, onboarding records, and performance records;
(e) Driver delivery acceptance and refusal records, subcontracting request and approval records, and multi-platform engagement data;
(f) SLG financial information, including but not limited to SLG's fiscal year 2024 revenue of approximately $312.7 million and EBITDA of approximately $28.4 million, and any other financial statements, projections, or business data provided in connection with the engagement;
(g) All attorney-client privileged communications between C&H and SLG, and between C&H and CRA, to the extent shared with CRA in connection with the engagement;
(h) All attorney work product prepared by C&H or at C&H's direction, including litigation strategies, legal analyses, case assessments, and settlement evaluations; and
(i) All draft reports, preliminary analyses, internal memoranda, working papers, and communications prepared by CRA at C&H's direction in anticipation of litigation or for the purpose of providing legal advice to SLG.
4.2 Obligations.  CRA shall maintain all Confidential Information in strict confidence and shall not disclose, disseminate, publish, or otherwise make available any Confidential Information to any third party without the prior written consent of C&H. CRA shall limit access to Confidential Information to those CRA employees, consultants, and agents who have a demonstrated need to know such information for the purpose of performing services under this Agreement, and CRA shall ensure that all such individuals are bound by written confidentiality obligations at least as protective as those contained in this Section 4. CRA shall implement and maintain reasonable administrative, technical, and physical security measures to protect Confidential Information from unauthorized access, use, disclosure, alteration, or destruction, consistent with industry standards for the protection of sensitive litigation materials.
4.3 Privilege and Work Product Protection
CRA acknowledges and agrees that its work under this Agreement is being performed at the direction of C&H, in anticipation of litigation, and for the purpose of assisting C&H in providing legal advice to SLG. CRA's preliminary analyses, draft reports, internal communications with C&H, and all other materials prepared by CRA at C&H's direction that are not designated for disclosure to opposing parties or the Court are intended to be protected by the attorney-client privilege and/or the work product doctrine to the fullest extent permitted by applicable law. CRA shall not disclose any draft reports, preliminary analyses, internal memoranda, working papers, or communications with C&H unless and until C&H expressly authorizes such disclosure in writing. CRA acknowledges that CRA's final testifying expert reports and declarations, once designated by C&H for disclosure pursuant to applicable rules of civil procedure or court order, may be subject to discovery by opposing parties and are not covered by the privilege protections described in this Section 4.3.
4.4 Return or Destruction of Materials
Upon termination or conclusion of the engagement, or at any time upon C&H's written request, CRA shall, at C&H's direction, either: (a) promptly return to C&H all Confidential Information in CRA's possession, custody, or control, including all copies, summaries, extracts, and derivative works thereof, in whatever form or medium; or (b) destroy all such Confidential Information and certify such destruction in writing to C&H within fifteen (15) calendar days of the date of destruction. Notwithstanding the foregoing, CRA may retain one archival copy of Confidential Information to the extent required by applicable law, regulation, or professional standards, provided that such retained copy shall remain subject to the confidentiality obligations set forth in this Section 4 for so long as it is maintained.
SECTION 5: DATA ACCESS AND HANDLING
5.1 Data to Be Provided
C&H shall arrange for CRA to receive access to the following data and documents from SLG in connection with CRA's performance of services under this Agreement:
(a) RouteSync dispatch records for all delivery drivers across all fourteen (14) SLG distribution hubs during the relevant period (April 30, 2022 through the present), including delivery assignment data, delivery completion data, and time-stamped dispatch records;
(b) GPS telematics data for all delivery drivers, including real-time location data, route adherence data, and stop-time records;
(c) Pay records for all 1,187 unique delivery drivers who performed services for SLG under an ICOA during the relevant period, including per-delivery payment amounts, weekly and monthly compensation summaries, and any adjustment or bonus payments;
(d) ICOA execution records, identifying which version of the ICOA (v1.0, v2.0, or v3.0) each driver executed, the date of execution, and the distribution hub to which each driver was assigned;
(e) Driver delivery acceptance and refusal logs, documenting each driver's delivery acceptance rate relative to the 85% minimum acceptance rate specified in the ICOAs, including any notices of non-compliance or warnings issued to drivers;
(f) Subcontracting request and approval records, documenting instances in which drivers requested authorization to engage subcontractors to perform deliveries and the disposition of such requests;
(g) Multi-platform engagement data, to the extent available in SLG's records, documenting the extent to which drivers simultaneously performed delivery services for other companies or platforms during the relevant period; and
(h) Hub-level operational policies and procedures for all fourteen (14) SLG distribution hubs, including any hub-specific supplements or modifications to the standard ICOA terms, dispatch protocols, or performance standards.
C&H shall use reasonable efforts to provide or arrange access to the foregoing data in a timely manner consistent with the deliverable deadlines set forth in Section 6 of this Agreement. CRA shall promptly notify C&H of any data gaps, quality issues, or additional data needs identified during the course of the engagement.
5.2 Data Security
CRA shall store all electronically transmitted data and Confidential Information received in connection with the engagement on encrypted, password-protected systems that meet or exceed industry-standard security protocols. CRA shall not transmit Confidential Information via unsecured email, unsecured file transfer services, or any other unsecured communication channel. CRA shall use secure file transfer protocols (SFTP) or equally secure methods for the transmission of electronic data between CRA and C&H. CRA shall comply with any electronically stored information ("ESI") protocols, protective orders, or data handling requirements established by the Court or agreed upon by the parties in the Litigation. CRA shall promptly notify C&H of any actual or suspected security breach involving Confidential Information.
SECTION 6: DELIVERABLES AND TIMELINE
6.1 Conditional Certification Phase Deliverables
CRA shall prepare and deliver the following work product during the conditional certification phase of the Litigation:
(a) Preliminary Analysis Report: An internal memorandum addressed to C&H summarizing CRA's initial statistical and economic findings regarding the similarly situated analysis, including preliminary observations regarding variance in key metrics across the driver population and across ICOA versions. The Preliminary Analysis Report shall be prepared for C&H's internal use in developing litigation strategy and shall be treated as attorney work product. Due Date: June 20, 2025.
(b) Expert Declaration: A final sworn declaration of Dr. Priya Ramanathan, executed under penalty of perjury, setting forth Dr. Ramanathan's expert opinions, the bases and reasons therefor, and the data, methodologies, and analyses upon which such opinions rely, in support of SLG's opposition to plaintiff's motion for conditional certification of the proposed FLSA collective. The Expert Declaration shall be delivered to C&H in final form sufficiently in advance of the filing deadline to allow C&H adequate time for review and incorporation into the opposition brief. Due Date: July 25, 2025 (in advance of the August 13, 2025 deadline for Defendant's response to plaintiff's motion for conditional certification).
6.2 Merits Phase Deliverables
Subject to C&H's further direction and the Court's scheduling order, CRA shall prepare and deliver the following work product during the merits phase of the Litigation:
(a) Expert Report: A full expert report compliant with the requirements of Federal Rule of Civil Procedure 26(a)(2)(B), including all required disclosures. The Expert Report shall set forth Dr. Ramanathan's complete expert opinions on the merits issues, including the economic reality test analysis and damages rebuttal, together with a complete statement of the bases and reasons for each opinion, the data and other information considered, all exhibits to be used in support of the opinions, Dr. Ramanathan's qualifications, a list of all cases in which Dr. Ramanathan has testified as an expert at trial or by deposition within the preceding four years, and a statement of the compensation to be paid for the study and testimony in this case. Due Date: To be determined by the Court's scheduling order; the current discovery cutoff is March 15, 2026, and the expert report deadline will be established in due course.
(b) Deposition Preparation: CRA shall make Dr. Ramanathan available for deposition preparation sessions with C&H and for expert deposition, as scheduled by the parties in accordance with the Court's scheduling order and applicable rules.
(c) Trial Preparation and Testimony: CRA shall make Dr. Ramanathan available for trial preparation sessions with C&H and for live testimony at trial. Trial is currently set for September 14, 2026, before the Honorable Rebecca Chen.
6.3 Additional Deliverables
CRA shall prepare and deliver such other analyses, memoranda, presentations, or work product as C&H may reasonably request in connection with the Litigation, subject to the budget parameters set forth in Section 3.2 and CRA's right to notification and approval for budget overages as set forth in Section 3.3.
SECTION 7: INDEPENDENCE AND OBJECTIVITY
7.1 Expert Independence
CRA and Dr. Ramanathan shall conduct all analyses under this Agreement independently and shall render opinions based solely upon their professional judgment, recognized methodologies in labor economics and applied statistics, and the data and information available to them. C&H acknowledges that CRA's conclusions and opinions must be scientifically and methodologically supportable and that CRA cannot and does not guarantee any particular outcome, conclusion, or opinion. C&H further acknowledges that Dr. Ramanathan's opinions, once formed, must be stated honestly and completely regardless of whether such opinions are favorable or unfavorable to SLG's position in the Litigation. CRA shall promptly notify C&H if, in the course of its analysis, CRA reaches any conclusion that may be adverse to SLG's position, so that C&H may evaluate the implications and provide further direction regarding the scope and use of CRA's work product.
7.2 No Conflicts
CRA represents and warrants that, as of the Effective Date of this Agreement, it has conducted a reasonable conflicts check and has identified no existing engagement, relationship, financial interest, or other circumstance that would create a conflict of interest with respect to the services to be performed under this Agreement. Specifically, CRA represents that neither CRA nor any of its principals, employees, or consultants has previously been engaged by or on behalf of Marcus Delano, Hartwell & Brashear PLLC, or any other party adverse to SLG in the Litigation, or has any personal, financial, or professional relationship with any such party that could reasonably be expected to compromise CRA's independence or objectivity. CRA shall promptly notify C&H in writing if any actual or potential conflict of interest arises during the course of the engagement, and the Parties shall confer in good faith regarding the appropriate course of action to address any such conflict.
SECTION 8: TERM AND TERMINATION
8.1 Term.  This Agreement shall be effective as of the Effective Date and shall continue in full force and effect until the earliest of: (a) the completion of all services described herein and the payment of all amounts due to CRA; (b) the final resolution of the Litigation, whether by judgment, settlement, dismissal, or otherwise; or (c) termination by either Party pursuant to Section 8.2 of this Agreement.
8.2 Termination.  Either Party may terminate this Agreement at any time, with or without cause, upon thirty (30) calendar days' prior written notice to the other Party, delivered in accordance with the notice provisions of Section 13.4 of this Agreement. In the event of termination by either Party, CRA shall be entitled to compensation for all services rendered and all expenses properly incurred through the effective date of termination, subject to the invoicing and payment provisions of Section 3.5. Upon termination, CRA shall promptly deliver to C&H all completed and partially completed work product in CRA's possession and shall comply with the confidentiality, data return, and data destruction provisions set forth in Sections 4 and 5 of this Agreement. C&H shall use reasonable efforts to provide CRA with sufficient notice of termination to allow for an orderly transition of the engagement.
8.3 Survival.  The following provisions of this Agreement shall survive the termination or expiration of this Agreement and shall continue in full force and effect indefinitely or for the period specified therein, as applicable: Section 4 (Confidentiality), Section 5.2 (Data Security), Section 9 (Indemnification), and Section 10 (Limitation of Liability). The survival of such provisions shall not be affected by the reason for termination or the Party that initiated the termination.
SECTION 9: INDEMNIFICATION
9.1 Indemnification by C&H / SLG
C&H, on behalf of SLG, shall indemnify, defend, and hold harmless CRA and its officers, members, managers, employees, agents, and consultants (each, a "CRA Indemnified Party") from and against any and all third-party claims, demands, actions, suits, losses, damages, liabilities, costs, and expenses (including reasonable attorneys' fees and court costs) arising out of or relating to CRA's performance of services under this Agreement or CRA's use of data or information provided by C&H or SLG, except to the extent that such claims, losses, or liabilities are caused by or result from CRA's gross negligence or willful misconduct in the performance of services under this Agreement.
9.2 Indemnification by CRA
CRA shall indemnify, defend, and hold harmless C&H and SLG, and their respective partners, officers, directors, employees, agents, and representatives (each, an "C&H/SLG Indemnified Party"), from and against any and all claims, demands, actions, suits, losses, damages, liabilities, costs, and expenses (including reasonable attorneys' fees and court costs) arising out of or relating to CRA's gross negligence or willful misconduct in the performance of services under this Agreement, including but not limited to any breach by CRA of its confidentiality or data security obligations under Sections 4 and 5 of this Agreement that is attributable to CRA's gross negligence or willful misconduct.
SECTION 10: LIMITATION OF LIABILITY
CRA's aggregate liability to C&H and SLG under this Agreement, whether arising in contract, tort, strict liability, or otherwise, shall not exceed the total amount of fees actually paid to CRA under this Agreement as of the date on which any claim for liability is asserted. In no event shall either Party be liable to the other Party for any indirect, incidental, consequential, special, exemplary, or punitive damages of any kind, including but not limited to lost profits, loss of business opportunity, or loss of data, arising out of or in connection with this Agreement or the services performed hereunder, regardless of whether such damages are foreseeable and regardless of whether such Party has been advised of the possibility of such damages. The limitations set forth in this Section 10 shall not apply to a Party's indemnification obligations under Section 9 or to any liability arising from a Party's willful misconduct or intentional breach of this Agreement.
SECTION 11: REPRESENTATIONS AND WARRANTIES
11.1 CRA Representations
CRA represents and warrants to C&H and SLG as follows:
(a) CRA is a limited liability company duly organized, validly existing, and in good standing under the laws of the Commonwealth of Virginia, and has all requisite power and authority to enter into this Agreement and to perform its obligations hereunder;
(b) Dr. Priya Ramanathan is a qualified expert in labor economics and statistical analysis, holds a Ph.D. in Economics, and has extensive experience providing expert economic and statistical analysis in FLSA collective actions, worker misclassification litigation, and related employment matters. Dr. Ramanathan has been qualified as an expert witness and has testified in federal and state courts in multiple jurisdictions;
(c) CRA has the capacity, personnel, and resources to perform the services described in this Agreement within the timelines specified herein and in accordance with the professional standards applicable to expert economic and statistical analysis in federal litigation; and
(d) The execution, delivery, and performance of this Agreement by CRA do not and will not conflict with or violate any agreement, obligation, or order to which CRA is a party or by which CRA is bound.
11.2 C&H Representations
C&H represents and warrants to CRA as follows:
(a) C&H is a limited liability partnership duly organized and existing under the laws of the State of New York and is authorized to practice law in the State of Texas;
(b) C&H is duly authorized to enter into this Agreement on behalf of SLG and to retain expert consultants in connection with the defense of the Litigation;
(c) C&H has obtained SLG's authorization for the engagement of CRA on the terms described herein, including the scope of services and the budget parameters set forth in Section 3; and
(d) C&H shall use reasonable efforts to provide CRA with timely access to the data, documents, and information necessary for CRA to perform its obligations under this Agreement.
SECTION 12: GOVERNING LAW AND DISPUTE RESOLUTION
This Agreement shall be governed by and construed in accordance with the laws of the State of Texas, without regard to the conflict of laws principles thereof. Any dispute, controversy, or claim arising out of or relating to this Agreement, or the breach, termination, or validity thereof, that cannot be resolved by good-faith negotiation between the Parties within thirty (30) calendar days after written notice of the dispute is given by one Party to the other, shall be finally resolved by binding arbitration administered in Dallas, Texas, under the Commercial Arbitration Rules of the American Arbitration Association then in effect. The arbitration shall be conducted by a single arbitrator mutually selected by the Parties. The arbitrator's decision shall be final and binding upon the Parties and may be entered as a judgment in any court of competent jurisdiction. Each Party shall bear its own costs and attorneys' fees in connection with any arbitration, unless the arbitrator determines that the award of costs and fees to the prevailing party is appropriate under the circumstances.
SECTION 13: MISCELLANEOUS
13.1 Entire Agreement
This Agreement, together with Exhibit A (Curriculum Vitae of Dr. Priya Ramanathan), Exhibit B (Fee Schedule), and Exhibit C (Matter Information), which are attached hereto and incorporated herein by reference, constitutes the entire agreement between the Parties with respect to the subject matter hereof and supersedes all prior and contemporaneous discussions, negotiations, understandings, representations, and agreements, whether oral or written, between the Parties relating to the subject matter of this Agreement.
13.2 Amendments.  This Agreement may not be amended, modified, or supplemented except by a written instrument duly executed by authorized representatives of both Parties. No oral modification, amendment, or waiver of any provision of this Agreement shall be effective.
13.3 Assignment.  Neither Party may assign, transfer, or delegate this Agreement or any of its rights or obligations hereunder without the prior written consent of the other Party, and any attempted assignment without such consent shall be null and void. Notwithstanding the foregoing, C&H may assign this Agreement to a successor law firm representing SLG in the Litigation, provided that C&H gives CRA prompt written notice of such assignment.
13.4 Notices.  All notices, requests, demands, consents, and other communications required or permitted under this Agreement shall be in writing and shall be deemed duly given when: (a) delivered personally; (b) sent by certified or registered United States mail, return receipt requested, postage prepaid; (c) sent by a nationally recognized overnight courier service; or (d) transmitted by email with confirmation of receipt, addressed as follows:
If to C&H:
Bernard Crawford, Partner Calderwood & Harkness LLP 2200 Ross Avenue, Suite 3600 Dallas, Texas 75201
Email: bcrawford@calderwoodharkness.com
If to CRA:
Dr. Priya Ramanathan, Managing Principal Corbin Risk Advisors LLC 1901 N. Moore Street, Suite 1020 Arlington, Virginia 22209
Email: pramanathan@corbinrisk.com
Either Party may change its address for purposes of this Section 13.4 by giving written notice thereof to the other Party in accordance with this Section.
13.5 Counterparts.  This Agreement may be executed in two or more counterparts, each of which shall be deemed an original and all of which together shall constitute one and the same instrument. Execution and delivery of this Agreement by electronic signature or by facsimile transmission of a signed counterpart shall be deemed to be, and shall have the same force and effect as, execution and delivery of an original signed counterpart.
13.6 Waiver.  The failure of either Party to enforce any provision of this Agreement at any time or for any period of time shall not constitute a waiver of such provision or of the right of such Party to enforce such provision or any other provision of this Agreement at any future time. No waiver of any provision of this Agreement shall be effective unless made in writing and signed by the waiving Party.
IN WITNESS WHEREOF, the Parties have executed this Expert Retention Agreement as of the date first written above.
CALDERWOOD & HARKNESS LLP
By: ________
Name: Bernard Crawford
Title: Partner, Labor & Employment Practice Group
Date: May 8, 2025
CORBIN RISK ADVISORS LLC
By: ________
Name: Dr. Priya Ramanathan
Title: Managing Principal
Date: May 8, 2025
EXHIBIT A
CURRICULUM VITAE OF DR. PRIYA RAMANATHAN
DR. PRIYA RAMANATHAN
Managing Principal Corbin Risk Advisors LLC 1901 N. Moore Street, Suite 1020 Arlington, Virginia 22209
EDUCATION.  Ph.D., Economics — University of Michigan, Ann Arbor, MI (2007) Dissertation: Structural Models of Labor Market Segmentation and Misclassification in the U.S. Transportation Sector
M.A., Economics — University of Michigan, Ann Arbor, MI (2004)
B.A., Mathematics and Economics (summa cum laude) — University of Virginia, Charlottesville, VA (2002)
PROFESSIONAL EXPERIENCE.  Managing Principal, Corbin Risk Advisors LLC, Arlington, VA (2016–Present)
Leads the firm's labor economics and employment litigation practice. Provides expert economic and statistical analysis in connection with FLSA collective actions, state wage-and-hour class actions, worker misclassification disputes, Title VII statistical analyses, and other employment-related litigation. Directs a team of associate consultants and analysts. Serves as testifying expert in federal and state courts nationwide.
Senior Economist, Bureau of Labor Statistics, U.S. Department of Labor, Washington, DC (2011–2016)
Led research projects on independent contractor classification trends and labor market dynamics in the logistics and transportation sectors. Developed statistical models for analyzing contingent workforce data and contributed to the redesign of the Current Population Survey Contingent Worker Supplement.
Assistant Professor, Department of Economics, George Mason University, Fairfax, VA (2007–2011)
Taught graduate and undergraduate courses in labor economics, econometrics, and applied statistics. Conducted peer-reviewed research on worker classification, wage determination, and overtime compensation in the gig economy and logistics industry.
EXPERT TESTIMONY EXPERIENCE
Dr. Ramanathan has been retained as a consulting or testifying expert in more than forty (40) matters involving FLSA collective actions, state wage-and-hour class actions, and worker misclassification litigation. Dr. Ramanathan has been qualified as an expert witness and has testified at trial or by deposition in the following representative matters, among others:
•  Reynolds et al. v. [National Parcel Delivery Company], U.S. District Court for the Eastern District of Pennsylvania (FLSA collective action, driver misclassification; testified at trial, 2024)
•  Carter v. [Regional Logistics Provider], U.S. District Court for the Middle District of Tennessee (FLSA collective action, conditional certification; deposition testimony, 2023)
•  [Multi-Plaintiff Class] v. [Technology Platform Company], Superior Court of California, County of Los Angeles (state wage-and-hour class action, gig worker classification; deposition testimony, 2022)
•  [Named Plaintiff] v. [Interstate Freight Carrier], U.S. District Court for the Northern District of Illinois (FLSA collective action, overtime and misclassification; testified at trial, 2021)
•  [Named Plaintiff] v. [Healthcare Staffing Agency], U.S. District Court for the Southern District of Texas (FLSA collective action, nurse contractor classification; deposition testimony, 2020)
Note: Client names have been replaced with generic descriptions in certain entries to maintain client confidentiality in accordance with applicable ethical obligations and prior engagement agreements.
Dr. Ramanathan has provided expert testimony at trial in seven (7) matters and by deposition in twenty-six (26) matters within the preceding four years.
SELECTED PUBLICATIONS.  
1.  Ramanathan, P. & Liu, J., "Statistical Approaches to the Similarly Situated Inquiry in FLSA Collective Actions," Journal of Labor Economics, Vol. 41, No. 3 (2023), pp. 487–522.
2.  Ramanathan, P., "Economic Reality and the Independent Contractor: A Quantitative Framework for Multifactor Classification Analysis," Industrial & Labor Relations Review, Vol. 75, No. 2 (2022), pp. 312–349.
3.  Ramanathan, P. & Okafor, C., "Variance and Commonality: Measuring Heterogeneity in Proposed FLSA Collectives," Stanford Law & Policy Review, Vol. 32, No. 1 (2021), pp. 89–128.
4.  Ramanathan, P., "Overtime Compensation and the Gig Economy: An Empirical Analysis of Misclassification in Last-Mile Delivery," Monthly Labor Review, U.S. Bureau of Labor Statistics (2019), pp. 1–24.
5.  Ramanathan, P. & Bergstrom, H., "Contingent Workers and Wage Dynamics in the U.S. Logistics Sector," American Economic Review: Papers & Proceedings, Vol. 108 (2018), pp. 201–205.
PROFESSIONAL AFFILIATIONS.  
•  American Economic Association (Member)
•  Society of Labor Economists (Member)
•  National Association of Forensic Economics (Fellow)
•  American Statistical Association, Section on Statistics in Business and Economic Statistics (Member)
PROFESSIONAL CERTIFICATIONS AND HONORS
•  Certified in Quantitative Finance (CQF), 2014
•  Bureau of Labor Statistics Commissioner's Award for Excellence in Research, 2015
•  University of Michigan, Rackham Graduate School Distinguished Dissertation Award, 2007
EXHIBIT B
FEE SCHEDULE
HOURLY RATES.  The following hourly rates shall apply to services performed by CRA under this Agreement:
Rates are effective as of the Effective Date (May 8, 2025) and shall remain fixed through the conditional certification phase of the Litigation. Rates for the merits phase may be adjusted by mutual written agreement of the Parties.
Time shall be recorded in increments of one-tenth (0.1) of an hour.
BUDGET SUMMARY.  
The Conditional Certification Phase budget of $175,000.00 includes $90,000.00 allocated as the expert preliminary analysis component within C&H's Phase 1 billing cap of $475,000.00 and $85,000.00 for additional analysis, the Expert Declaration, and related work through the conditional certification ruling.
The Total Estimated Budget Through Trial of $450,000.00 covers all CRA services from engagement through trial, including expanded merits-phase analysis, preparation of the Rule 26(a)(2)(B) Expert Report, deposition preparation and testimony, and trial preparation and testimony.
EXPENSE REIMBURSEMENT POLICY
CRA shall be reimbursed for reasonable, documented out-of-pocket expenses incurred in connection with the engagement, including:
•  Airfare (coach class, unless otherwise pre-approved by C&H)
•  Ground transportation (taxi, rideshare, rental car)
•  Hotel/lodging (at reasonable rates consistent with market norms for the travel destination)
•  Meals (while traveling in connection with the engagement)
•  Data acquisition costs directly related to the engagement
•  Specialized software or computing costs directly attributable to the engagement
•  Printing, reproduction, and binding costs
•  Courier and delivery charges
Travel expenses for any single expenditure exceeding $1,000.00 shall require C&H's prior written approval. All expenses shall be documented with receipts and itemized on CRA's monthly invoices. Expenses are billed separately from professional fees and are not included in the fee budget amounts set forth above.
EXHIBIT C
MATTER INFORMATION
CASE INFORMATION.  
CLIENT INFORMATION.  
CALDERWOOD & HARKNESS LLP — MATTER TEAM
All C&H team members are located in the firm's Dallas office at 2200 Ross Avenue, Suite 3600, Dallas, Texas 75201.
KEY DEADLINES.  
This Exhibit C is provided for reference purposes and is current as of the Effective Date. Deadlines and other scheduling information are subject to modification by order of the Court. C&H shall promptly notify CRA of any changes to the information set forth herein that are material to CRA's performance of services under the Agreement.
[END OF AGREEMENT AND EXHIBITS]
Timekeeper | Hourly Rate
Dr. Priya Ramanathan (Lead Consultant) | $550.00 per hour
Associate Consultants | $375.00 per hour
Timekeeper | Title / Role | Hourly Rate
Dr. Priya Ramanathan | Lead Consultant / Testifying Expert | $550.00
Associate Consultants (as approved) | Associate-Level Analysts and Consultants | $375.00
Phase | Estimated Fee Budget
Conditional Certification Phase | $175,000.00
Merits Phase (incremental to conditional certification phase) | $275,000.00
Total Estimated Budget Through Trial | $450,000.00
Item | Detail
Case Caption | Delano v. Stonefield Logistics Group Inc.
Case Number | 3:25-cv-01847-RBC
Court | United States District Court for the Northern District of Texas, Dallas Division
Presiding Judge | Hon. Rebecca Chen, U.S. District Judge
Magistrate Judge | Hon. Timothy Farrell, U.S. Magistrate Judge
Item | Detail
Client Name | Stonefield Logistics Group Inc.
State of Incorporation | Delaware
Headquarters | 4200 Commerce Gateway Blvd., Suite 800, Irving, TX 75039
Role | Name
Responsible Partner | Bernard Crawford
Billing Partner | Renata Vasquez
Lead Associate | James Underwood
Working Associate | Devon Archer
Paralegal | Lisa Cheng
Deadline | Date
Defendant's Response to Plaintiff's Motion for Conditional Certification | August 13, 2025
CRA Preliminary Analysis Report Due to C&H (internal) | June 20, 2025
CRA Expert Declaration Due to C&H | July 25, 2025
Discovery Cutoff | March 15, 2026
Dispositive Motion Deadline | April 30, 2026
Trial | September 14, 2026

EXPERT RETENTION AGREEMENT

EXPERT RETENTION AGREEMENT

RECITALS. WHEREAS:

SECTION 1: ENGAGEMENT AND SCOPE OF SERVICES

SECTION 2: LEAD CONSULTANT AND STAFFING

SECTION 3: FEES AND BILLING

SECTION 4: CONFIDENTIALITY

SECTION 5: DATA ACCESS AND HANDLING

SECTION 6: DELIVERABLES AND TIMELINE

SECTION 7: INDEPENDENCE AND OBJECTIVITY

SECTION 8: TERM AND TERMINATION

SECTION 9: INDEMNIFICATION

SECTION 10: LIMITATION OF LIABILITY

SECTION 11: REPRESENTATIONS AND WARRANTIES

SECTION 12: GOVERNING LAW AND DISPUTE RESOLUTION

SECTION 13: MISCELLANEOUS

CALDERWOOD & HARKNESS LLP

CORBIN RISK ADVISORS LLC

EXHIBIT A

CURRICULUM VITAE OF DR. PRIYA RAMANATHAN

DR. PRIYA RAMANATHAN

EXPERT TESTIMONY EXPERIENCE

SELECTED PUBLICATIONS.

PROFESSIONAL AFFILIATIONS.

PROFESSIONAL CERTIFICATIONS AND HONORS

Record

Parties

Dates

Amounts