MEMORANDUM

MEMORANDUM
PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT
This memorandum is a privileged and confidential attorney-client communication and attorney work product prepared in anticipation of litigation. It is not intended for disclosure to any third party and should not be disclosed without the prior written consent of Calderwood & Harkness LLP. Disclosure of this memorandum to any unauthorized person may result in waiver of applicable privileges.
From: Nadia Petrov, Lead Associate, and James Underwood, Associate, Calderwood & Harkness LLP
To: Bernard Crawford, Responsible Partner; Renata Vasquez, Billing Partner
cc: Devin K. Arroyo, General Counsel, Verimark Hospitality Group Inc.
Date: February 3, 2026
Re: Custodian Identification for Litigation Hold — Pre-Litigation Wage-and-Hour Audit, Verimark Hospitality Group Inc.
Matter No.: 1021-00005
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I. Purpose and Background
The purpose of this memorandum is to identify all twenty-three (23) custodians whose documents and electronically stored information ("ESI") are subject to the litigation hold arising from the pre-litigation demand letter dated January 14, 2026 (the "Demand Letter"), sent by Garza, Linden & Okafor LLP ("GLO") on behalf of Daniela M. Serrano ("Serrano" or the "Claimant"). The Demand Letter was prepared under the supervision of Marco A. Garza, lead counsel, and Priya N. Chandrasekaran, associate, at GLO. Serrano is a former front-desk associate at the Verimark Regency Tampa property (Employee ID: VHG-EMP-20220314-5587), who was employed by Verimark Hospitality Group Inc. ("VHG" or the "Company") from March 14, 2022 through August 22, 2025.
The Demand Letter sets forth five principal categories of allegations against VHG:
(1) FLSA Overtime Violations. Systematic violations of the overtime provisions of the Fair Labor Standards Act, 29 U.S.C. § 207(a), arising from the alleged failure to properly compensate hourly, non-exempt employees for all hours worked in excess of forty (40) hours per workweek, including time worked before and after scheduled shifts that was not captured in VHG's timekeeping system.
(2) Illegal Automatic Meal-Break Deductions. The alleged practice of automatically deducting thirty (30) minutes of compensable time from employee time records for meal breaks, regardless of whether the employee actually received a bona fide, duty-free meal period, resulting in systematic underpayment of wages.
(3) Uncompensated Pre- and Post-Shift Work. The alleged requirement that hourly employees perform compensable work activities before and after their recorded shifts — including, but not limited to, computer system boot-up, shift-handover briefings, donning and doffing of uniforms, and preparation of workstations — without recording such time or receiving compensation therefor.
(4) Florida Minimum Wage Violations for Tipped Employees. Violations of the Florida minimum wage requirements for tipped employees under Article X, Section 24 of the Florida Constitution, including the alleged failure to ensure that the combination of direct wages and tips received by tipped employees equaled or exceeded the applicable Florida minimum wage during all pay periods.
(5) Exemption Misclassification. The alleged misclassification of certain "lead" and "senior" hourly roles (such as "Senior Front-Desk Associate" and "Lead Housekeeping Attendant") as exempt from FLSA overtime requirements under the administrative exemption, when such positions allegedly did not satisfy the duties test or salary-basis test for the administrative exemption under 29 C.F.R. Part 541.
The Demand Letter asserts these claims on behalf of a putative class and FLSA collective consisting of all current and former hourly, non-exempt employees at Verimark-branded Florida properties from January 2023 to the present. Based on VHG's internal records and the representations in the Demand Letter, the putative class/collective is estimated to encompass approximately 4,100 to 5,900 individuals. The Demand Letter demands payment of $18.5 million, representing alleged back pay, liquidated damages, and attorneys' fees.
VHG's General Counsel, Devin K. Arroyo, received the Demand Letter on January 16, 2026. In consultation with Mr. Arroyo, VHG issued an internal litigation-hold memorandum on January 17, 2026, directing the preservation of all documents and ESI potentially relevant to the claims asserted in the Demand Letter. This memorandum supplements VHG's internal litigation hold by providing a comprehensive custodian list, identifying each custodian's title, affiliated property, and the specific categories of data under their control that are subject to the preservation obligation.
Properties at Issue. The Demand Letter identifies seven (7) VHG-branded properties spanning the Tampa Bay, Orlando, and South Florida markets. Six of these properties are directly owned and operated by VHG. The seventh property — Verimark Shores Clearwater — is owned by Palomar Realty Partners LLC ("Palomar") and managed by VHG pursuant to Hotel Management Agreement HMA-2021-0601-PC, dated June 1, 2021 (the "Palomar HMA"). Under the Palomar HMA, VHG directly employs all on-site staff at the Verimark Shores Clearwater, which gives rise to potential joint-employer considerations that are addressed in a separate analysis. The seven at-issue properties are:
1.  Verimark Regency Tampa — Tampa, FL
2.  Verimark Grand Orlando — Orlando, FL
3.  Verimark Shores Clearwater — Clearwater Beach, FL (Palomar-owned; VHG-managed)
4.  Verimark Bayfront St. Petersburg — St. Petersburg, FL
5.  Verimark Resort & Spa Boca Raton — Boca Raton, FL
6.  Verimark Oceanview Fort Lauderdale — Fort Lauderdale, FL
7.  Verimark Key West Collection — Key West, FL
Applicable Lookback Periods and Preservation Date Range. The allegations in the Demand Letter implicate multiple statutes of limitations, each with a different lookback period calculated from the date of the Demand Letter (January 14, 2026):
•  FLSA — Willful Violation (3 years): January 14, 2023 to present, pursuant to 29 U.S.C. § 255(a).
•  FLSA — Non-Willful Violation (2 years): January 14, 2024 to present, pursuant to 29 U.S.C. § 255(a).
•  Florida Minimum Wage Claims (5 years): January 14, 2021 to present, pursuant to Fla. Stat. § 95.11(2)(b), which governs actions founded on a liability created by statute.
Because the Florida minimum wage claims carry the longest applicable limitations period, and because the Demand Letter expressly asserts willfulness (which would extend the FLSA lookback to three years), preservation should cover the broadest applicable period. Accordingly, the data preservation date range established for this litigation hold is January 1, 2021 to the present. We have used January 1, 2021 rather than January 14, 2021 to provide a reasonable buffer and to capture complete pay periods and calendar-year records.
The engagement of Calderwood & Harkness LLP to represent VHG in this matter was authorized by the VHG Board of Directors and Audit Committee on January 29, 2026. The response deadline to the GLO Demand Letter is February 28, 2026.
II. Custodian Categories Overview
Based on our review of VHG's organizational structure, the allegations in the Demand Letter, the nature of the data and ESI likely to be relevant to the claims, and our initial consultations with Mr. Arroyo and Ms. Whitfield, we have identified a total of twenty-three (23) custodians whose documents and ESI are subject to the litigation hold. These custodians are organized into four categories, reflecting their organizational roles and the nature of the relevant information under their control:
Category A — Corporate Officers and Functional Leaders (4 custodians). These individuals hold enterprise-wide responsibilities for human resources, payroll and workforce compliance, legal affairs, and information technology. Their files contain corporate policies, system-wide configuration records, and overarching compliance documentation relevant to all seven at-issue properties. The four Category A custodians are:
1.  Carla S. Whitfield — Vice President, Human Resources
2.  Enrique J. Fuentes — Director, Payroll & Workforce Compliance
3.  Devin K. Arroyo — General Counsel
4.  Malik P. Jefferson — Corporate IT Administrator
Category B — Property-Level Human Resources Managers (7 custodians). One HR Manager has been identified for each of the seven at-issue properties. These individuals maintain property-level HR files, handle employee onboarding and offboarding, administer local meal-break and scheduling practices, and serve as the first-line contacts for employee complaints regarding pay and hours worked. They are the primary repositories of property-specific personnel records, scheduling documentation, and employee-complaint logs.
Category C — Property-Level General Managers (7 custodians). One General Manager has been identified for each of the seven at-issue properties. General Managers oversee daily hotel operations, approve overtime, set scheduling and operational procedures (including pre-shift briefings and uniform requirements), and have direct knowledge of practices related to meal breaks, off-the-clock work, and tipped-employee arrangements at their respective properties.
Category D — Department Heads at Selected Properties (5 custodians). Five department heads have been identified across the seven at-issue properties based on the relevance of their specific departments to the allegations — principally front-desk operations, food and beverage operations involving tipped employees, and housekeeping operations involving uniform donning/doffing practices. The selection of these custodians was prioritized based on the three largest properties by hourly employee count and those with the most complex operational practices relevant to the Demand Letter allegations.
The combined total is: 4 (Corporate) + 7 (Property HR Managers) + 7 (Property GMs) + 5 (Department Heads) = 23 custodians.
Each custodian is described in detail in Sections III through VI below. A consolidated summary table appears in Section VII. The enterprise-wide data systems subject to preservation are identified in Section VIII, and implementation steps are outlined in Section IX.
III. Category A — Corporate Officers and Functional Leaders
The four custodians in this category hold positions at VHG's corporate headquarters and exercise enterprise-wide oversight over the functional areas most directly implicated by the Demand Letter — human resources, payroll and timekeeping, legal compliance, and information technology infrastructure.
III.A. Carla S. Whitfield — Vice President, Human Resources
Full Name: Carla S. Whitfield
Title: Vice President, Human Resources
Location: VHG Corporate Headquarters, 2400 Bayshore Boulevard, Suite 1100, Tampa, FL 33629
Organizational Scope: Ms. Whitfield exercises enterprise-wide oversight over all human resources functions across VHG's fourteen (14) Florida properties, including the seven at-issue properties identified in the Demand Letter. She reports directly to the Chief Executive Officer and is a member of the executive leadership team. Ms. Whitfield is responsible for the development, promulgation, and enforcement of all company-wide HR policies, including those directly at issue in this matter — specifically, meal-break policies, overtime authorization procedures, tip-pool policies, and employee classification and exemption designation procedures. She also oversees the property-level HR Managers identified in Category B.
Data Sources Under Her Control:
•  Corporate HR policy files, including the VHG Employee Handbook (current version v.7.2, effective January 1, 2025) and all prior versions in effect during the preservation period (January 1, 2021 to present). Prior versions include, at minimum, v.5.0 (effective January 1, 2021), v.6.0 (effective January 1, 2023), and v.7.0 (effective January 1, 2024).
•  Meal-break policies, including the automatic meal-break deduction policy and any revisions thereto, as well as any guidance memoranda or training materials distributed to property-level managers regarding meal-break administration.
•  Uniform and donning/doffing policies, including any directives regarding pre-shift and post-shift procedures and whether such time is compensable.
•  Overtime authorization procedures, including any changes to authorization thresholds or approval workflows during the preservation period.
•  Tip-pool policies, including tip-credit disclosures, tip-pool participation agreements, and any revisions to tip-distribution methodologies.
•  Employee classification and exemption designation records, including the documentation supporting the classification of "lead" and "senior" hourly roles (such as "Senior Front-Desk Associate," "Lead Housekeeping Attendant," and similar titles) as exempt from FLSA overtime requirements under the administrative exemption.
•  Internal HR audit reports and compliance reviews, including any wage-and-hour compliance assessments or self-audits conducted during the preservation period.
•  Correspondence with property-level HR Managers regarding labor practices, employee complaints, and policy implementation.
•  Corporate email (VHG corporate email system, Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
•  Physical HR files maintained at the corporate headquarters, including hard-copy policy binders, signed acknowledgment forms, and any handwritten notes or memoranda.
Ms. Whitfield's files are central to every allegation category because she is the architect and enforcer of the enterprise-wide policies that the Demand Letter alleges are unlawful.
III.B. Enrique J. Fuentes — Director, Payroll & Workforce Compliance
Full Name: Enrique J. Fuentes
Title: Director, Payroll & Workforce Compliance
Location: VHG Corporate Headquarters, 2400 Bayshore Boulevard, Suite 1100, Tampa, FL 33629
Organizational Scope: Mr. Fuentes oversees payroll processing, timekeeping system administration, and workforce compliance for all VHG properties. He is the primary VHG contact for Luminos Payroll Solutions Inc. ("Luminos"), the third-party vendor that provides VHG's timekeeping and payroll processing platform (Luminos TimeTrack). Mr. Fuentes is responsible for configuring and maintaining the timekeeping rules within the Luminos TimeTrack system, including the automatic meal-break deduction rule at the center of one of the Demand Letter's principal allegations.
Data Sources Under His Control:
•  Luminos TimeTrack system administration records (VHG account ID: LTT-VHG-2022-0041), including the configuration and change history of auto-deduction rule AR-MEAL-030. Rule AR-MEAL-030 is configured to automatically deduct thirty (30) minutes of compensable time from employee time records for any shift of six (6) hours or longer, regardless of whether the employee actually took an uninterrupted, duty-free meal break.
•  Payroll registers and wage statements for all seven at-issue properties, covering all pay periods within the preservation window.
•  Correspondence with Luminos Payroll Solutions Inc. (Shannon D. Prewitt, Senior Account Manager), including communications regarding system configuration, rule changes, data exports, and any issues or discrepancies identified in payroll processing.
•  Time-rounding policy documentation, including the specific rounding methodology (e.g., quarter-hour rounding) applied to employee time punches and any analysis of whether the rounding policy is neutral over time.
•  Overtime calculation methodology and algorithm settings, including the definition of the workweek, treatment of multiple rates of pay, and calculation of the regular rate for overtime purposes.
•  Tip-credit and tip-pool calculation records, including the methodology used to determine whether tipped employees' total compensation met or exceeded the applicable Florida minimum wage in each pay period.
•  Reports and analyses regarding payroll discrepancies, corrections, and exception requests from auto-deductions, including any logs of instances in which employees or supervisors submitted requests to reverse or modify automatic meal-break deductions.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
Mr. Fuentes's files are critical to all five allegation categories but are especially central to the overtime, automatic meal-break deduction, and tipped-employee minimum wage claims, as he controls the systems and configurations that generate the payroll and timekeeping records at the heart of those claims.
III.C. Devin K. Arroyo — General Counsel
Full Name: Devin K. Arroyo
Title: General Counsel
Location: VHG Corporate Headquarters, 2400 Bayshore Boulevard, Suite 1100, Tampa, FL 33629
Organizational Scope: Mr. Arroyo serves as VHG's chief legal officer and is responsible for legal compliance, litigation oversight, management of outside counsel relationships, and coordination with VHG's employment practices liability ("EPL") insurer. He is the recipient of the Demand Letter and the signatory on VHG's internal litigation-hold memorandum. Mr. Arroyo also oversees the legal aspects of the Palomar HMA and communications with Palomar's Managing Member, Ricardo E. Montalvo, regarding labor and employment matters at the Verimark Shores Clearwater property.
Data Sources Under His Control:
•  The Demand Letter from Garza, Linden & Okafor LLP dated January 14, 2026, and all related pre-litigation correspondence exchanged with GLO.
•  The internal litigation-hold memorandum dated January 17, 2026, and all records documenting the implementation and dissemination of the litigation hold.
•  Prior internal legal memoranda or opinions regarding wage-and-hour compliance, including any assessments of the legality of the automatic meal-break deduction policy, the classification of "lead" and "senior" roles as exempt, or the tip-pool and tip-credit practices.
•  Communications with Calderwood & Harkness LLP (Bernard Crawford, Nadia Petrov, James Underwood, and other Calderwood & Harkness personnel) regarding the engagement, strategy, and work product in this matter.
•  Communications with Pinnacle Indemnity Corp. regarding VHG's EPL insurance policy (Policy No. PIN-EPL-2025-44781), including notice of the claim, coverage analysis, and any reservation-of-rights correspondence.
•  The Hotel Management Agreement HMA-2021-0601-PC between VHG and Palomar Realty Partners LLC, together with all amendments, exhibits, and side letters thereto.
•  Communications with Palomar Realty Partners LLC (Ricardo E. Montalvo, Managing Member) regarding the managed property (Verimark Shores Clearwater), including any discussions of labor practices, staffing decisions, employment costs, or joint-employer considerations.
•  Prior employee complaints, demand letters, or agency charges (including any charges filed with the Equal Employment Opportunity Commission, the U.S. Department of Labor, or the Florida Department of Economic Opportunity) related to wage-and-hour issues at any of the seven at-issue properties.
•  Board of Directors and Audit Committee materials related to the engagement authorization dated January 29, 2026, including board resolutions, presentation materials, and minutes.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
Note regarding privilege: Certain documents within Mr. Arroyo's files may be subject to the attorney-client privilege, the work-product doctrine, or both. The inclusion of Mr. Arroyo as a custodian for purposes of document preservation does not constitute a waiver of any privilege. All documents collected from Mr. Arroyo's files will be reviewed for privilege before any production or disclosure.
III.D. Malik P. Jefferson — Corporate IT Administrator
Full Name: Malik P. Jefferson
Title: Corporate IT Administrator
Location: VHG Corporate Headquarters, 2400 Bayshore Boulevard, Suite 1100, Tampa, FL 33629
Organizational Scope: Mr. Jefferson manages VHG's enterprise IT infrastructure, including corporate email servers, electronic data storage systems, network shared drives, cloud storage, and the integration of VHG's internal systems with third-party platforms (including Luminos TimeTrack). He is responsible for the administration and enforcement of VHG's data retention and destruction policies and has the technical capability to implement system-level preservation measures across all relevant platforms.
Data Sources Under His Control:
•  Email server backup and archiving systems for all VHG custodians, including archived email data for any custodians whose email accounts may have been subject to routine deletion or turnover during the preservation period.
•  Luminos TimeTrack system integration logs and data-feed records, documenting the transfer of timekeeping data between VHG's internal systems and the Luminos platform.
•  IT system access logs for timekeeping and payroll systems, including records of who accessed, modified, or exported data from these systems during the preservation period.
•  Data retention and destruction policies and schedules, including the VHG Corporate Records Retention Policy (current version and all prior versions in effect since January 1, 2021) and any records of destruction events that occurred during the preservation period.
•  Electronic document management system ("DMS") records, including metadata and access logs for documents stored in VHG's corporate DMS.
•  Network shared drives and cloud storage repositories (including Sundial Systems and Cobalt Ridge Systems) containing HR, payroll, scheduling, and operational data for the at-issue properties.
•  System administration records for property-level point-of-sale ("POS") systems, scheduling software, and any other applications that record employee hours, tips, or operational activities.
Critical Coordination Note: Mr. Jefferson's role is essential for ensuring the technical preservation of ESI across all enterprise-wide systems. Calderwood & Harkness will coordinate directly with Mr. Jefferson to issue system-level suspension of all automated data-deletion routines, backup tape recycling schedules, and any other processes that could result in the destruction or alteration of relevant ESI. This coordination should be completed no later than February 7, 2026, to ensure that the preservation measures are in place well in advance of the February 28, 2026 response deadline to the GLO Demand Letter.
IV. Category B — Property-Level Human Resources Managers (7 Custodians)
One Human Resources Manager has been identified for each of the seven at-issue properties. These individuals are the primary custodians of property-level HR records, including personnel files, scheduling documentation, meal-break exception and complaint logs, employee onboarding and classification records, and tip-pool participation records. They handle employee onboarding and offboarding at their respective properties, administer local meal-break and scheduling practices in accordance with corporate policy, and serve as the first-line contacts for employee complaints regarding pay and hours worked. Because each property operates with some degree of local variation in the administration of corporate policies — particularly with respect to scheduling, meal-break practices, and tip-pool arrangements — the property-level HR Managers are essential custodians for understanding the on-the-ground implementation of the policies challenged in the Demand Letter.
IV.A. Patricia D. Salazar — Verimark Regency Tampa
Custodian Name: Patricia D. Salazar
Title: Human Resources Manager
Property: Verimark Regency Tampa, 1200 North Westshore Boulevard, Tampa, FL 33607
Property Details: The Verimark Regency Tampa is a 320-room full-service hotel with approximately 410 total employees, of whom an estimated 295 are hourly, non-exempt employees. This property is of particular significance to the litigation hold because it is the former work location of Daniela M. Serrano, the named Claimant.
Data Sources:
•  Property-level personnel files for all hourly employees at the Verimark Regency Tampa, including employment applications, offer letters, position descriptions, signed acknowledgment forms, performance evaluations, and disciplinary records.
•  Local scheduling records and shift rosters, including daily and weekly schedules for all departments.
•  Meal-break exception and complaint logs, including any documentation of instances in which employees reported that they were unable to take a full, duty-free meal break or in which supervisors noted meal-break interruptions.
•  Employee onboarding and classification records, including documentation supporting the exempt or non-exempt classification of each hourly position.
•  Tip-pool participation records for front-desk and concierge staff, including tip-pool sign-up forms, distribution logs, and any employee complaints or objections regarding tip-pool practices.
•  Local HR correspondence, including communications with employees, supervisors, and corporate HR regarding pay, hours worked, scheduling, and complaints.
•  Daniela M. Serrano's complete personnel file (Employee ID: VHG-EMP-20220314-5587), including her employment application, offer letter, position description, signed handbook and policy acknowledgments, performance evaluations, disciplinary records, and separation documentation. This file should be preserved and segregated immediately, as it will be among the first documents reviewed in connection with the Demand Letter.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
IV.B. Derek L. Nguyen — Verimark Grand Orlando
Custodian Name: Derek L. Nguyen
Title: Human Resources Manager
Property: Verimark Grand Orlando, 8750 International Drive, Orlando, FL 32819
Property Details: The Verimark Grand Orlando is a 485-room full-service resort and convention hotel with approximately 580 total employees, of whom an estimated 420 are hourly, non-exempt employees. This is the largest of the seven at-issue properties by total employee count and hourly employee count, making it a high-priority custodian location for document collection.
Data Sources:
•  Property-level personnel files for all hourly employees, including employment applications, offer letters, position descriptions, signed acknowledgment forms, performance evaluations, and disciplinary records.
•  Local scheduling records and shift rosters for all departments.
•  Meal-break exception logs and overtime authorization records, including documentation of meal-break exceptions, supervisor overrides, and overtime approval workflows.
•  Employee classification documentation for "lead" and "senior" roles, including the job descriptions, duties tests, and salary-basis documentation used to classify any such positions as exempt from FLSA overtime requirements. The Verimark Grand Orlando is believed to have a higher concentration of "lead" and "senior" classified positions than the other at-issue properties due to its size and operational complexity.
•  Tip-pool records for all tipped-employee positions, including front-desk, concierge, bell staff, and food and beverage service staff.
•  Employee complaints regarding pay and hours worked, including any formal or informal grievances, written complaints, or HR investigation records.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
IV.C. Rosa M. Fuentes-Delgado — Verimark Shores Clearwater
Custodian Name: Rosa M. Fuentes-Delgado
Title: Human Resources Manager
Property: Verimark Shores Clearwater, 455 Mandalay Avenue, Clearwater Beach, FL 33767
Property Details: The Verimark Shores Clearwater is a 210-room beachfront resort with approximately 260 total employees, of whom an estimated 190 are hourly, non-exempt employees.
Ownership Note: Unlike the other six at-issue properties, the Verimark Shores Clearwater is not directly owned by VHG. The property is owned by Palomar Realty Partners LLC ("Palomar"), and Ricardo E. Montalvo serves as Palomar's Managing Member. VHG manages the property under Hotel Management Agreement HMA-2021-0601-PC, dated June 1, 2021. Under the terms of the Palomar HMA, VHG directly employs all on-site staff at the Verimark Shores Clearwater, sets employment terms and conditions, and administers HR policies. This arrangement may give rise to a joint-employer analysis under the FLSA and Florida law, and Ms. Fuentes-Delgado's files are relevant to understanding the degree to which Palomar exercised (or did not exercise) control over the terms and conditions of employment at this property.
Data Sources:
•  Property-level personnel files for all hourly employees, including employment applications, offer letters, position descriptions, signed acknowledgment forms, performance evaluations, and disciplinary records.
•  Local scheduling records and shift rosters for all departments.
•  Meal-break and overtime records, including exception logs and supervisor override documentation.
•  Any documentation reflecting instructions, directives, or communications from Palomar Realty Partners LLC (Ricardo E. Montalvo or other Palomar representatives) regarding staffing levels, labor practices, scheduling, compensation, or operational procedures at the Verimark Shores Clearwater.
•  Tip-pool records for all tipped-employee positions.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
IV.D. Tyrone K. Mitcham — Verimark Bayfront St. Petersburg
Custodian Name: Tyrone K. Mitcham
Title: Human Resources Manager
Property: Verimark Bayfront St. Petersburg, 100 First Avenue South, St. Petersburg, FL 33701
Property Details: The Verimark Bayfront St. Petersburg is a 275-room waterfront hotel with approximately 340 total employees, of whom an estimated 245 are hourly, non-exempt employees.
Data Sources:
•  Property-level personnel files for all hourly employees, including employment applications, offer letters, position descriptions, signed acknowledgment forms, performance evaluations, and disciplinary records.
•  Local scheduling records and shift rosters for all departments.
•  Meal-break exception logs and overtime records, including documentation of meal-break interruptions, exception requests, and overtime authorization approvals.
•  Employee classification records, including documentation supporting the classification of any "lead" or "senior" hourly positions.
•  Tip-pool records for all tipped-employee positions.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
IV.E. Vanessa A. Rowe — Verimark Resort & Spa Boca Raton
Custodian Name: Vanessa A. Rowe
Title: Human Resources Manager
Property: Verimark Resort & Spa Boca Raton, 2600 North Ocean Boulevard, Boca Raton, FL 33431
Property Details: The Verimark Resort & Spa Boca Raton is a 390-room luxury resort and spa with approximately 470 total employees, of whom an estimated 340 are hourly, non-exempt employees. This property has the second-highest hourly employee count among the seven at-issue properties.
Data Sources:
•  Property-level personnel files for all hourly employees, including employment applications, offer letters, position descriptions, signed acknowledgment forms, performance evaluations, and disciplinary records.
•  Local scheduling records and shift rosters for all departments.
•  Meal-break and overtime records, including exception logs and supervisor override documentation.
•  Employee classification records for "lead" and "senior" roles, particularly the "Senior Front-Desk Associate" position, which the Demand Letter specifically identifies as potentially misclassified. Documentation supporting the exempt classification of this role — including the position description, duties analysis, and salary records — should be prioritized for collection from Ms. Rowe's files.
•  Tip-pool records for all tipped-employee positions, including front-desk, concierge, bell staff, and spa service staff.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
IV.F. Craig W. Hendricks — Verimark Oceanview Fort Lauderdale
Custodian Name: Craig W. Hendricks
Title: Human Resources Manager
Property: Verimark Oceanview Fort Lauderdale, 3030 Holiday Drive, Fort Lauderdale, FL 33316
Property Details: The Verimark Oceanview Fort Lauderdale is a 305-room oceanfront hotel with approximately 365 total employees, of whom an estimated 265 are hourly, non-exempt employees.
Data Sources:
•  Property-level personnel files for all hourly employees, including employment applications, offer letters, position descriptions, signed acknowledgment forms, performance evaluations, and disciplinary records.
•  Local scheduling records and shift rosters for all departments.
•  Meal-break and overtime records, including exception logs and supervisor override documentation.
•  Employee classification records for any "lead" or "senior" hourly positions.
•  Tip-pool records for all tipped-employee positions.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
IV.G. Linda S. Yamamoto — Verimark Key West Collection
Custodian Name: Linda S. Yamamoto
Title: Human Resources Manager
Property: Verimark Key West Collection, 1500 Reynolds Street, Key West, FL 33040
Property Details: The Verimark Key West Collection is a 150-room boutique resort comprising multiple historic buildings. The property has approximately 195 total employees, of whom an estimated 140 are hourly, non-exempt employees. Although this is the smallest of the seven at-issue properties by employee count, it operates in a unique geographic market with its own scheduling and operational challenges that may be relevant to the off-the-clock and meal-break allegations.
Data Sources:
•  Property-level personnel files for all hourly employees, including employment applications, offer letters, position descriptions, signed acknowledgment forms, performance evaluations, and disciplinary records.
•  Local scheduling records and shift rosters for all departments.
•  Meal-break and overtime records, including exception logs and supervisor override documentation.
•  Employee classification records for any "lead" or "senior" hourly positions.
•  Tip-pool records for all tipped-employee positions.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
V. Category C — Property-Level General Managers (7 Custodians)
One General Manager has been identified for each of the seven at-issue properties. General Managers are custodians because they exercise day-to-day oversight of all hotel operations at their respective properties, approve overtime, set scheduling and operational procedures — including pre-shift briefings, post-shift handover procedures, and uniform requirements — and possess direct knowledge of practices related to meal breaks, off-the-clock work, and tipped-employee arrangements. General Managers also communicate regularly with corporate leadership regarding operational issues, staffing levels, labor costs, and compliance matters, and their files are likely to contain directives, memoranda, and correspondence reflecting property-level implementation of the corporate policies at issue in the Demand Letter.
V.A. Franklin J. Benavides — Verimark Regency Tampa
Custodian Name: Franklin J. Benavides
Title: General Manager
Property: Verimark Regency Tampa, 1200 North Westshore Boulevard, Tampa, FL 33607
Significance: As the General Manager of the Claimant's former work location, Mr. Benavides is a high-priority custodian. He may have direct knowledge of the operational practices that Serrano alleges gave rise to uncompensated pre- and post-shift work, as well as the on-call meal-break practices and tip-pool arrangements at the Verimark Regency Tampa.
Data Sources:
•  Operational directives regarding shift procedures, including instructions to employees and department heads regarding pre-shift activities (such as computer system boot-up, workstation preparation, uniform donning, and shift-handover briefings) and post-shift activities (such as workstation closeout, uniform doffing, and end-of-shift reporting).
•  Overtime authorization approvals, including records of overtime requests, approvals, and denials, as well as any communications regarding overtime budgets or cost-containment initiatives.
•  Communications with department heads (including Karen P. Strickland, Director of Front Office Operations) regarding staffing, scheduling, operational procedures, and employee complaints.
•  Knowledge of on-call meal-break practices, including any directives or understandings regarding whether employees were expected to remain on-call or available to respond to work demands during their scheduled meal breaks.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
V.B. Miriam T. Osei — Verimark Grand Orlando
Custodian Name: Miriam T. Osei
Title: General Manager
Property: Verimark Grand Orlando, 8750 International Drive, Orlando, FL 32819
Significance: As the General Manager of VHG's largest Florida property, Ms. Osei oversees a complex multi-departmental operation with a substantial hourly workforce. Her files are expected to contain operational directives, overtime management communications, and staffing plans that are relevant across multiple allegation categories.
Data Sources:
•  Operational directives regarding shift procedures, pre-shift and post-shift activities, uniform requirements, and shift-handover protocols for all departments.
•  Overtime authorization approvals and communications regarding overtime budgets, staffing levels, and labor cost management.
•  Communications with department heads (including Antoine R. Beckford, Director of Food & Beverage, and Claudia F. Espinosa, Director of Rooms Division) regarding staffing, scheduling, operational procedures, and employee complaints.
•  Knowledge of meal-break practices and any communications regarding the administration of on-call meal breaks across departments.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
V.C. Douglas R. Patel — Verimark Shores Clearwater
Custodian Name: Douglas R. Patel
Title: General Manager
Property: Verimark Shores Clearwater, 455 Mandalay Avenue, Clearwater Beach, FL 33767
Special Note — Palomar Realty Partners LLC: Mr. Patel's files are of particular significance because of the managed-property arrangement between VHG and Palomar Realty Partners LLC. Mr. Patel may have communications with Palomar's Managing Member, Ricardo E. Montalvo, or other Palomar representatives regarding operational oversight, staffing decisions, labor costs, and any Palomar directives that affected the terms and conditions of employment at the Verimark Shores Clearwater. Such communications are directly relevant to the joint-employer analysis that will be required in connection with this property.
Data Sources:
•  Operational directives regarding shift procedures, pre-shift and post-shift activities, uniform requirements, and shift-handover protocols.
•  Overtime authorization approvals and communications regarding overtime budgets and staffing levels.
•  Communications with Palomar Realty Partners LLC (Ricardo E. Montalvo and any other Palomar personnel), including any directives, instructions, or discussions regarding staffing levels, employment costs, scheduling, labor practices, or operational standards at the Verimark Shores Clearwater.
•  Staffing records, including any documentation reflecting Palomar's involvement in or approval of hiring, termination, or staffing-level decisions.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
V.D. Angela C. Dougherty — Verimark Bayfront St. Petersburg
Custodian Name: Angela C. Dougherty
Title: General Manager
Property: Verimark Bayfront St. Petersburg, 100 First Avenue South, St. Petersburg, FL 33701
Data Sources:
•  Operational directives regarding shift procedures, pre-shift and post-shift activities, uniform requirements, and shift-handover protocols.
•  Overtime authorization approvals and communications regarding overtime budgets and staffing levels.
•  Communications with department heads regarding staffing, scheduling, operational procedures, and employee complaints.
•  Knowledge of meal-break practices and any communications regarding on-call meal-break expectations at this property.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
V.E. Raymond K. Almeida — Verimark Resort & Spa Boca Raton
Custodian Name: Raymond K. Almeida
Title: General Manager
Property: Verimark Resort & Spa Boca Raton, 2600 North Ocean Boulevard, Boca Raton, FL 33431
Data Sources:
•  Operational directives regarding shift procedures, pre-shift and post-shift activities, uniform requirements, and shift-handover protocols.
•  Overtime authorization approvals and communications regarding overtime budgets and staffing levels.
•  Communications with department heads (including Nathan W. Gilmore, Director of Front Office Operations) regarding staffing, scheduling, operational procedures, and employee complaints.
•  Knowledge of meal-break practices and communications regarding on-call meal-break expectations at this property.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
V.F. Joanna L. Brandt — Verimark Oceanview Fort Lauderdale
Custodian Name: Joanna L. Brandt
Title: General Manager
Property: Verimark Oceanview Fort Lauderdale, 3030 Holiday Drive, Fort Lauderdale, FL 33316
Data Sources:
•  Operational directives regarding shift procedures, pre-shift and post-shift activities, uniform requirements, and shift-handover protocols.
•  Overtime authorization approvals and communications regarding overtime budgets and staffing levels.
•  Communications with department heads regarding staffing, scheduling, operational procedures, and employee complaints.
•  Knowledge of meal-break practices and communications regarding on-call meal-break expectations at this property.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
V.G. Samuel E. Fisk — Verimark Key West Collection
Custodian Name: Samuel E. Fisk
Title: General Manager
Property: Verimark Key West Collection, 1500 Reynolds Street, Key West, FL 33040
Data Sources:
•  Operational directives regarding shift procedures, pre-shift and post-shift activities, uniform requirements, and shift-handover protocols.
•  Overtime authorization approvals and communications regarding overtime budgets and staffing levels.
•  Communications with department heads regarding staffing, scheduling, operational procedures, and employee complaints.
•  Knowledge of meal-break practices and communications regarding on-call meal-break expectations at this property.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
VI. Category D — Department Heads (5 Custodians)
Five department heads have been identified across the seven at-issue properties based on the relevance of their specific departments to the allegations in the Demand Letter. The department heads selected are those whose functional areas are most directly implicated by the claims — specifically, front-desk operations (relevant to the Claimant's position, pre- and post-shift off-the-clock work, and tip-pool practices), food and beverage operations (relevant to tipped-employee minimum wage claims), and housekeeping/rooms-division operations (relevant to uniform donning/doffing and off-the-clock claims). The selection of these five custodians was prioritized based on the three largest properties by hourly employee count (Verimark Grand Orlando, Verimark Resort & Spa Boca Raton, and Verimark Regency Tampa) and the property with the most complex ownership structure (Verimark Shores Clearwater).
VI.A. Karen P. Strickland — Director of Front Office Operations, Verimark Regency Tampa
Custodian Name: Karen P. Strickland
Title: Director of Front Office Operations
Property: Verimark Regency Tampa, 1200 North Westshore Boulevard, Tampa, FL 33607
Relevance: Ms. Strickland was the direct supervisor of Daniela M. Serrano and other front-desk associates at the Verimark Regency Tampa. She has direct, first-hand knowledge of the pre-shift computer boot-up procedures, shift-handover briefing practices, on-call meal-break expectations, and tip-pool arrangements for front-desk and concierge staff at this property. Her files are expected to contain the specific operational directives and standard operating procedures that Serrano alleges resulted in uncompensated off-the-clock work and improper meal-break deductions.
Data Sources:
•  Shift schedules and staffing plans for front-desk operations, including daily rosters, shift-assignment records, and any modifications made due to staffing shortages or operational demands.
•  Training materials and standard operating procedures ("SOPs") for front-desk associates, including SOPs for shift start-up (computer boot-up, system log-in, cash drawer verification), shift handover, guest check-in/check-out, and shift closeout.
•  Pre-shift and post-shift task checklists, including any written or electronic checklists that detail the tasks employees are expected to complete before and after their scheduled shifts.
•  Tip-pool distribution records for front-desk and concierge staff, including the methodology for calculating and distributing pooled tips, participation records, and any employee complaints or disputes regarding tip distributions.
•  Performance evaluations and disciplinary records for front-desk staff, including any records relating to Daniela M. Serrano.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
VI.B. Antoine R. Beckford — Director of Food & Beverage, Verimark Grand Orlando
Custodian Name: Antoine R. Beckford
Title: Director of Food & Beverage
Property: Verimark Grand Orlando, 8750 International Drive, Orlando, FL 32819
Relevance: The Verimark Grand Orlando is VHG's largest Florida property by employee count (580 total), and its food and beverage department has a significant tipped-employee population, including servers, bartenders, room-service attendants, and banquet staff. Mr. Beckford's files are relevant to the tipped-employee minimum wage claims (Allegation Category 4) because he oversees tip-pool practices, tip-credit disclosures, and tipped-employee compensation at the property's multiple restaurants, bars, and banquet facilities. His files are also relevant to the meal-break and off-the-clock claims as they pertain to F&B staff.
Data Sources:
•  F&B department scheduling and shift records, including daily and weekly rosters for all F&B outlets (restaurants, bars, room service, banquets, and catering).
•  Tip distribution and tip-pool documentation, including tip-pool participation agreements, daily tip distribution records, banquet gratuity allocation records, and any analyses of whether tipped employees' total compensation met the applicable Florida minimum wage.
•  Meal-break and on-call practices specific to F&B operations, including any directives regarding whether F&B staff may take uninterrupted, duty-free meal breaks during service periods, and documentation of meal-break interruptions or exceptions.
•  Uniform and donning/doffing requirements for F&B staff, including any requirements for employees to change into or out of uniforms, aprons, or other work attire before or after their recorded shifts.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
VI.C. Claudia F. Espinosa — Director of Rooms Division, Verimark Grand Orlando
Custodian Name: Claudia F. Espinosa
Title: Director of Rooms Division (including Housekeeping)
Property: Verimark Grand Orlando, 8750 International Drive, Orlando, FL 32819
Relevance: The housekeeping staff at the Verimark Grand Orlando represent one of the largest hourly workforce populations at any single VHG property. The donning and doffing of housekeeping uniforms and the pre-shift preparation of supply carts and equipment are among the specific activities that the Demand Letter alleges constitute uncompensated off-the-clock work. In addition, the housekeeping department at the Verimark Grand Orlando has historically experienced a high concentration of overtime, making Ms. Espinosa's files relevant to the FLSA overtime allegations as well.
Data Sources:
•  Housekeeping department scheduling and shift records, including daily room-assignment sheets, shift rosters, and any modifications made due to occupancy fluctuations or staffing shortages.
•  Uniform distribution and locker-room procedures, including any written policies or practices regarding where and when housekeeping staff are required to change into and out of their uniforms, and whether such time is compensable.
•  Pre-shift and post-shift time requirements, including the time required for uniform changes, supply cart preparation and stocking, linen inventory, and end-of-shift equipment return and cleaning.
•  Overtime logs and approval records, including documentation of overtime hours worked, overtime authorization requests and approvals, and any communications regarding overtime budgets or cost-containment measures specific to the housekeeping department.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
VI.D. Nathan W. Gilmore — Director of Front Office Operations, Verimark Resort & Spa Boca Raton
Custodian Name: Nathan W. Gilmore
Title: Director of Front Office Operations
Property: Verimark Resort & Spa Boca Raton, 2600 North Ocean Boulevard, Boca Raton, FL 33431
Relevance: The Verimark Resort & Spa Boca Raton has the second-largest hourly employee count among the at-issue properties (an estimated 340 hourly employees). Mr. Gilmore oversees the front-desk and concierge operations at this luxury property, including tip-pool practices for front-desk and concierge employees. Of particular significance, the Verimark Resort & Spa Boca Raton employs individuals in the "Senior Front-Desk Associate" role, which the Demand Letter specifically identifies as potentially misclassified as exempt under the FLSA administrative exemption. Mr. Gilmore's files may contain job descriptions, duties analyses, and classification documentation relevant to the exemption misclassification allegation (Allegation Category 5).
Data Sources:
•  Front-office scheduling and shift records, including daily and weekly rosters, shift-assignment records, and staffing plans.
•  Tip-pool records for front-desk and concierge employees, including participation agreements, distribution logs, and any analyses of tip-credit compliance.
•  Job descriptions and classification records for "senior" and "lead" front-desk roles, including the position descriptions, duties summaries, and any documentation supporting the determination that such roles qualify for the FLSA administrative exemption.
•  Pre-shift and post-shift task procedures, including written or electronic checklists for shift start-up and closeout activities.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
VI.E. Beatrice H. Kovacs — Director of Operations, Verimark Shores Clearwater
Custodian Name: Beatrice H. Kovacs
Title: Director of Operations
Property: Verimark Shores Clearwater, 455 Mandalay Avenue, Clearwater Beach, FL 33767
Relevance: Ms. Kovacs holds the Director of Operations title at the Palomar-owned, VHG-managed Verimark Shores Clearwater. In this capacity, she has direct knowledge of day-to-day operational decisions at the property, including staffing, scheduling, shift procedures, and meal-break practices. Critically, Ms. Kovacs may also have direct knowledge of any involvement by Palomar Realty Partners LLC in labor-related matters at the property — including any directives from Palomar regarding staffing levels, labor cost targets, or operational standards — which is directly relevant to the joint-employer analysis.
Data Sources:
•  Operational scheduling and staffing records for all departments at the Verimark Shores Clearwater.
•  Communications with Palomar Realty Partners LLC (Ricardo E. Montalvo and other Palomar personnel) regarding operations, staffing, labor practices, employment costs, and any operational directives from the property owner.
•  Meal-break, overtime, and shift-handover procedures, including any written policies, SOPs, or directives governing these practices at the Verimark Shores Clearwater.
•  Corporate email (Ashgrove Software), calendar entries, and instant messaging (Northgate Data Systems).
VII. Consolidated Custodian Table
The following table provides a consolidated summary of all twenty-three (23) custodians identified in this memorandum:
Roll-Up Total: 4 Corporate Officers/Functional Leaders + 7 Property HR Managers + 7 Property General Managers + 5 Department Heads = 23 Custodians
VIII. Data Sources and Systems Subject to Preservation
In addition to the custodian-specific data sources identified in Sections III through VI, the following enterprise-wide data systems contain relevant ESI for all or most custodians and are subject to the litigation hold. Preservation of these systems should be coordinated centrally through Malik P. Jefferson (Corporate IT Administrator) and Enrique J. Fuentes (Director, Payroll & Workforce Compliance), as indicated below.
VIII.A. Luminos TimeTrack (Account ID: LTT-VHG-2022-0041)
The Luminos TimeTrack platform, provided by Luminos Payroll Solutions Inc., is VHG's enterprise-wide timekeeping system. It captures time-punch records for all hourly employees at all VHG properties and is the primary source of timekeeping data for the seven at-issue properties. The following categories of data within the Luminos TimeTrack system are subject to the litigation hold:
•  Time-punch records from January 1, 2021 to present for all hourly employees at the seven at-issue properties. (Note: The Luminos TimeTrack system was implemented by VHG in 2022 under account ID LTT-VHG-2022-0041. For the period January 1, 2021 through the implementation date, timekeeping records may reside in VHG's prior timekeeping system, and Mr. Fuentes and Mr. Jefferson should be consulted to identify and preserve those legacy records.)
•  Auto-deduction rule AR-MEAL-030 configuration and complete change history, including the date the rule was implemented, any modifications to the rule parameters, and the identity of the individual(s) who configured or modified the rule.
•  Exception and correction logs, reflecting all instances in which employees or supervisors submitted requests to adjust, reverse, or override automatic meal-break deductions.
•  Overtime calculation algorithm and settings, including the definition of the workweek, treatment of multiple pay rates, and regular-rate calculation methodology.
•  All system audit logs, user access logs, and data export records.
A formal data preservation request letter was sent by Calderwood & Harkness LLP to Shannon D. Prewitt, Senior Account Manager, Luminos Payroll Solutions Inc., 3300 Peachtree Road NE, Suite 800, Atlanta, GA 30326, on January 24, 2026. We are awaiting confirmation of receipt and compliance. Follow-up is recommended if confirmation is not received by February 7, 2026.
VIII.B. Corporate Email and Messaging Systems
VHG uses Ashgrove Software as its enterprise email and messaging platform. All email accounts for the twenty-three (23) identified custodians must be preserved from January 1, 2021 to the present, including:
•  Email (inbox, sent items, deleted items, archive folders, and any local .pst or .ost files).
•  Calendar entries and meeting invitations.
•  Northgate Data Systems instant messaging conversations, including one-on-one chats, group chats, and channel messages.
•  Larkspur Health IT files associated with each custodian's account.
Malik P. Jefferson must be directed to suspend any auto-deletion policies applicable to email accounts and Northgate Data Systems data, including any retention policies that automatically purge email older than a specified period or that empty the "Deleted Items" folder on a scheduled basis. This suspension must be applied to all twenty-three custodian accounts and should remain in effect until the litigation hold is formally released.
VIII.C. VHG HRIS (Human Resources Information System)
VHG maintains a centralized Human Resources Information System containing employee records for all properties. The following categories of data within the HRIS are subject to preservation:
•  Employee demographic records, including names, addresses, contact information, and Social Security numbers (for identification purposes).
•  Job classification records, including position titles, department codes, FLSA exemption designations, and the dates and reasons for any changes in classification.
•  Compensation histories, including base pay rates, tip-credit amounts, and any changes in compensation during the preservation period.
•  Hire dates, separation dates, and reasons for separation for all hourly employees at the seven at-issue properties.
•  Exemption classification records, including documentation of the duties test and salary-basis test analyses performed for any positions classified as exempt.
VIII.D. Payroll Registers and Wage Statements
Payroll registers and individual wage statements (pay stubs) for all hourly employees at the seven at-issue properties must be preserved for the entire preservation period (January 1, 2021 to present). These records are generated by Luminos Payroll Solutions Inc. and include:
•  Pay-period-level payroll registers showing gross pay, hours worked (regular and overtime), deductions, tip income, and net pay for each employee.
•  Individual wage statements (pay stubs) issued to employees, including the detail of hours worked, pay rates applied, overtime hours and premium pay, tip-credit amounts, and deductions.
•  Payroll adjustment and correction records, including any retroactive pay adjustments issued during the preservation period.
VIII.E. Property-Level Scheduling Software
Each of the seven at-issue properties uses scheduling software to create, publish, and modify employee shift schedules. The specific scheduling platform may vary by property. The following categories of data are subject to preservation:
•  Published shift schedules, including the originally published schedule and any subsequent modifications, for all departments at each property.
•  Shift assignments, including the assignment of specific employees to specific shifts, positions, and work areas.
•  Schedule modification logs, including records of shift swaps, cancellations, additions, and the reasons therefor.
Mr. Jefferson should confirm the identity of the scheduling software platform used at each property and ensure that data preservation measures are in place for each.
VIII.F. Physical / Hard-Copy Records
In addition to ESI, certain relevant records may exist in physical or hard-copy form. The following categories of physical records are subject to the litigation hold:
•  Personnel files maintained at property HR offices, including original signed employment applications, offer letters, position descriptions, and acknowledgment forms.
•  Tip-pool sign-up