ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT DO NOT DISTRIBUTE WITHOUT PRIOR AUTHORIZATION FROM CALDERWOOD & HARKNESS LLP

ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT DO NOT DISTRIBUTE WITHOUT PRIOR AUTHORIZATION FROM CALDERWOOD & HARKNESS LLP
DOCUMENT AND DATA COLLECTION REQUEST LIST
WAGE-AND-HOUR PRE-LITIGATION AUDIT
Addressees:
Devin K. Arroyo, General Counsel, Verimark Hospitality Group Inc.
Carla S. Whitfield, Vice President, Human Resources, Verimark Hospitality Group Inc.
Enrique J. Fuentes, Director, Payroll & Workforce Compliance, Verimark Hospitality Group Inc.
Copy to:
Shannon D. Prewitt, Senior Account Manager, Luminos Payroll Solutions Inc. (for requests directed to Luminos only — see Section II.F below)
I. INTRODUCTION AND PURPOSE
This Document and Data Collection Request List (this "Request List") identifies all documents and electronically stored information ("ESI") that Calderwood & Harkness LLP ("Calderwood & Harkness" or "Outside Counsel") requires from Verimark Hospitality Group Inc. ("VHG" or the "Company") and from its payroll processor, Luminos Payroll Solutions Inc. ("Luminos"), in connection with the pre-litigation wage-and-hour audit (the "Audit") being conducted at the direction of VHG's General Counsel. The Audit arises from the demand letter dated January 14, 2026, sent by Garza, Linden & Okafor LLP ("Claimant's Counsel") on behalf of former employee Daniela M. Serrano (Employee ID: VHG-EMP-20220314-5587) (the "Claimant"), which was received by VHG's General Counsel on January 15, 2026, and which asserts putative individual and collective-action claims under federal and Florida state wage-and-hour law.
The purpose of the Audit, and of this Request List, is to evaluate the five categories of allegations set forth in the demand letter, namely:
1.  Unpaid overtime under Section 207(a) of the Fair Labor Standards Act, 29 U.S.C. § 207(a), including allegations that VHG failed to pay one-and-one-half times the regular rate of pay for hours worked in excess of forty (40) in a workweek;
2.  Improper automatic meal-break deductions, specifically the allegation that VHG's timekeeping system automatically deducts thirty (30) minutes per qualifying shift for a meal break regardless of whether the employee actually received an uninterrupted, duty-free meal period;
3.  Uncompensated pre-shift and post-shift work, including allegations that hourly employees were required to perform work activities — such as donning and doffing uniforms, attending shift-handover briefings, booting up and shutting down computer systems, and reviewing guest-services logs — before clocking in or after clocking out, and that such time was not compensated;
4.  Florida tipped-employee minimum-wage non-compliance under Article X, Section 24 of the Florida Constitution, including allegations that VHG failed to satisfy the notice and documentation requirements for the tip credit and failed to ensure that tipped employees' combined direct wages and tips equaled or exceeded the full applicable minimum wage; and
5.  Alleged misclassification of "lead" and "senior" hourly roles under the FLSA administrative exemption, 29 C.F.R. Part 541, including the allegation that certain positions bearing "lead" or "senior" designations were improperly classified as exempt from overtime requirements notwithstanding that the duties actually performed by employees in those roles did not satisfy the administrative-exemption duties test.
This Request List supports the scoping phase of the Audit and the forthcoming engagement of Ridgepoint Advisory Group LLC ("Ridgepoint") as forensic payroll analytics consultant, pending approval of the engagement letter by VHG's Audit Committee. Once Ridgepoint is formally engaged, certain data specifications in this Request List may be supplemented or refined based on Ridgepoint's data-ingestion requirements and sampling methodology.
Calderwood & Harkness emphasizes that timely and complete production of the documents and data identified herein is essential. The response deadline for the Claimant's demand letter is February 28, 2026, and the preliminary exposure assessment that will inform VHG's response strategy depends on the data identified in the priority categories below.
II. GENERAL INSTRUCTIONS
The following general instructions apply to all requests set forth in Section III of this Request List unless a specific request states otherwise. VHG and Luminos personnel responsible for collection and production should review these instructions carefully before beginning the collection process.
A. Scope — Properties at Issue
All requests in this Request List apply to the following seven Verimark-branded properties (collectively, the "At-Issue Properties") unless a specific request states otherwise:
These seven properties represent VHG's most significant Florida operations by employee headcount and revenue and are the properties identified in the demand letter as locations where the alleged practices occurred or are likely to have occurred. Where specifically noted in a request below, certain requests also apply to VHG's remaining seven Florida properties and to corporate-level records maintained at VHG's headquarters at 2400 Bayshore Boulevard, Suite 1100, Tampa, FL 33629.
B. Date Range
Unless otherwise specified in a particular request, all documents and data should cover the period from January 1, 2021 through the present date (February 3, 2026) (the "Relevant Period").
The rationale for this date range is as follows: the longest potentially applicable limitations period for the claims at issue is five (5) years under Section 95.11(2)(b) of the Florida Statutes for Florida constitutional minimum-wage claims, which, measured from the date of the demand letter (January 14, 2026), produces a lookback date of January 14, 2021. The January 1, 2021 start date is used for administrative convenience to capture complete pay periods that may straddle mid-January 2021. The FLSA overtime and minimum-wage claims carry a shorter limitations period of two (2) years (or three years for willful violations) under 29 U.S.C. § 255(a), but given the Claimant's allegation of willfulness and the possibility that the Audit will identify systemic issues warranting review over a longer period, the five-year lookback is applied uniformly.
Certain requests may specify a narrower date range. In particular, requests directed to Luminos may specify a start date of January 1, 2022, coinciding with VHG's transition to the Luminos TimeTrack timekeeping system and Luminos payroll-processing services.
C. Format Requirements
The following format requirements apply to all productions:
•  Electronic data exports (timekeeping, payroll, HRIS): Provide in native format where possible, including .csv, .xlsx, .xml, or other delimited-text or structured-data exports from the Luminos TimeTrack system, VHG's HRIS, and any predecessor timekeeping or payroll systems. If native format is unavailable, searchable PDF with OCR text is acceptable but should be used only as a last resort for data-intensive records. Large datasets (e.g., complete time-punch records, payroll registers) should be provided as delimited text files (.csv) or Excel workbooks (.xlsx) with column headers clearly identifying all data fields.
•  Paper records: Where documents exist only in hard copy, scan to searchable PDF with OCR enabled. Apply sequential Bates numbering in the format VHG-WHA-000001 through the end of production. Maintain a Bates log correlating document descriptions, custodians, and Bates ranges.
•  Email and electronic communications: Produce in .pst (Microsoft Outlook), .mbox, or comparable native format with all metadata intact, including sender, recipient(s), date/time, subject line, and attachment information. If native-format production is not feasible for certain custodians, load files compatible with standard review platforms (e.g., Relativity, Everlaw) are acceptable, provided all metadata fields are preserved.
•  Metadata: All electronic files should include, at minimum, the following metadata fields: creation date, last-modified date, author, custodian, file name, file path, and file size. Do not strip or alter metadata during collection or production.
•  Password-protected files: If any responsive documents are password-protected, provide the password or an unprotected version. Note the existence of the password protection in the production log.
D. Custodians.  Refer to the Custodian Identification Memorandum dated January 31, 2026, prepared by Calderwood & Harkness, which identifies twenty-three (23) custodians whose files should be searched and, to the extent responsive, collected and produced. The identified custodians include:
•  The seven (7) property-level Human Resources Managers at each of the At-Issue Properties;
•  The seven (7) property-level General Managers at each of the At-Issue Properties;
•  Carla S. Whitfield, Vice President, Human Resources, VHG;
•  Enrique J. Fuentes, Director, Payroll & Workforce Compliance, VHG;
•  Devin K. Arroyo, General Counsel, VHG;
•  Malik P. Jefferson, Corporate IT Administrator, VHG; and
•  Five (5) designated department heads at VHG corporate and property levels, as identified in the Custodian Identification Memorandum.
Any documents, data, or ESI within the custody, control, or possession of these individuals that are responsive to the categories described in Section III below should be collected and produced. If any custodian identifies additional individuals who may possess responsive materials, VHG should notify Calderwood & Harkness promptly so that the custodian list can be updated.
E. Privilege.  All documents produced to Calderwood & Harkness in connection with this Audit are being provided in furtherance of VHG's request for legal advice and are subject to the protections of the attorney-client privilege and the attorney work-product doctrine. The following specific instructions apply:
1.  VHG and its personnel should not produce any documents responsive to this Request List to any third party — including Claimant's Counsel, governmental agencies, co-defendants, or any other person or entity — without the prior written approval of Calderwood & Harkness.
2.  Any documents located during the collection process that may be subject to a pre-existing privilege — for example, prior legal opinions on wage-and-hour compliance, communications with prior outside counsel, or internal legal memoranda prepared by VHG's General Counsel — should be flagged and logged separately on a privilege log. Do not produce such documents to Calderwood & Harkness until the privilege-log entries have been reviewed and a determination made regarding whether the documents should be shared with Outside Counsel under the common-interest doctrine or otherwise.
3.  Inadvertent production of privileged documents by VHG will not constitute a waiver of privilege. Calderwood & Harkness will implement clawback protocols, as described in Section IV.C below, to address any inadvertent disclosures.
F. Coordination with Luminos Payroll Solutions Inc.
Requests within this Request List that are identified with the designation "[Luminos]" are directed, in whole or in part, to Luminos Payroll Solutions Inc. The relevant account details are as follows:
•  Account Number: LTT-VHG-2022-0041
•  Senior Account Manager: Shannon D. Prewitt
•  Address: 3300 Peachtree Road NE, Suite 800, Atlanta, GA 30326
Calderwood & Harkness has separately issued a Data Preservation Request Letter to Luminos dated February 6, 2026, directing Luminos to preserve all data, records, and system-configuration information relating to VHG's account for the period from January 1, 2022 through the present.
VHG should facilitate data exports from the Luminos TimeTrack system to the extent the data can be pulled through VHG's administrative portal, including time-punch data, payroll registers, and exception reports. Requests requiring Luminos back-end access, system-configuration documentation, or historical configuration records that are not accessible through VHG's administrative portal will be coordinated directly by Calderwood & Harkness with Ms. Prewitt. VHG's designated coordinator (Mr. Fuentes) should notify Calderwood & Harkness if any requested data cannot be exported through the VHG administrative portal so that the request can be redirected to Luminos.
G. Response Deadline
Initial production of all responsive documents and data is requested on or before February 17, 2026, with rolling supplementation thereafter as additional documents are located, collected, or made available.
Priority items — specifically, Category 1 (Timekeeping Data and Records) and Category 2 (Payroll Records and Wage Statements) — should be produced by February 10, 2026, if practicable. This expedited timeline is necessary to support the preliminary exposure assessment and the preparation of the draft response to the demand letter, for which the response deadline is February 28, 2026. If VHG or Luminos anticipates difficulty meeting the February 10, 2026 deadline for Priority items, please contact Nadia Petrov immediately to discuss an alternative production schedule.
Calderwood & Harkness reserves the right to issue supplemental requests as the Audit progresses and as additional information needs are identified, including any requests arising from Ridgepoint's forensic payroll analytics once Ridgepoint is formally engaged.
III. REQUEST CATEGORIES
CATEGORY 1: TIMEKEEPING DATA AND RECORDS [PRIORITY]
Category 1 requests address the core timekeeping data that will form the foundation of the overtime, meal-break, and off-the-clock analyses. Given the centrality of this data to the preliminary exposure assessment, Category 1 is designated as a Priority category, and VHG and Luminos are requested to prioritize production of these items by February 10, 2026.
Request 1.1 — Luminos TimeTrack Electronic Time-Punch Data [Luminos / VHG]
Produce a complete export of all employee time-punch records (including clock-in, clock-out, break-in, and break-out punches) from the Luminos TimeTrack system (System ID: LTT-VHG-2022-0041) for all hourly, non-exempt employees at each of the seven At-Issue Properties.
Date Range: January 1, 2022 through the present date (coinciding with VHG's adoption of the Luminos TimeTrack system).
Format: .csv or delimited text file. The export should include, at a minimum, the following data fields for each time-punch record:
(a) Employee ID;
(b) Employee name (last, first, middle initial);
(c) Property code;
(d) Department code;
(e) Job code;
(f) Date of punch;
(g) Clock-in time (in HH:MM:SS format, including AM/PM designation or 24-hour format);
(h) Clock-out time (in HH:MM:SS format);
(i) Break start time (for each break taken);
(j) Break end time (for each break taken);
(k) Total hours recorded for the shift;
(l) Overtime hours recorded for the shift or pay period;
(m) Any edits, overrides, or manual adjustments to the punch record, including the timestamp of the edit and the user ID of the person making the edit;
(n) Reason code or notation associated with any edit or override;
(o) Pay period identifier; and
(p) Any flags or indicators applied by the system (e.g., missed-punch flags, meal-break exception flags, overtime alert flags).
The export should include all historical punch data stored in the Luminos TimeTrack system, not only current-period data. If the Luminos system archives historical data to a separate data store or backup, include that archived data as well. To the extent that the export requires coordination with Luminos back-end support, Calderwood & Harkness will facilitate that coordination directly with Ms. Prewitt.
Request 1.2 — Pre-Luminos Timekeeping Records (Pre-January 2022) [VHG]
Produce all timekeeping records maintained by VHG or its prior payroll processor(s) for the period January 1, 2021 through December 31, 2021 (i.e., the period before VHG's transition to the Luminos TimeTrack system) for all hourly, non-exempt employees at each of the seven At-Issue Properties.
In connection with this request, VHG should identify:
(a) The timekeeping system(s) used at each At-Issue Property during this period, including the vendor name, system name, and version;
(b) The format in which pre-Luminos timekeeping records are available (e.g., electronic export, paper timesheets, scanned images);
(c) Whether any pre-Luminos timekeeping data was migrated to the Luminos TimeTrack system at the time of transition, and if so, the scope of the migrated data and the format; and
(d) Whether any pre-Luminos timekeeping data was archived, deleted, or otherwise disposed of, and if so, the date and circumstances of such disposition.
If pre-Luminos timekeeping records exist only in paper format, scan to searchable PDF with Bates numbering as specified in Section II.C above.
Request 1.3 — Automatic Meal-Break Deduction Configuration Records [Luminos]
Produce complete documentation of the automatic meal-break deduction rule identified within the Luminos TimeTrack system as AR-MEAL-030 (or any successor or related rule identifier), including the following:
(a) The rule parameters as currently configured, including the deduction amount (thirty (30) minutes), the shift-length threshold triggering the deduction (shifts of six (6) or more hours), and any additional conditions or parameters;
(b) The effective date on which the AR-MEAL-030 rule was first implemented in the Luminos TimeTrack system for VHG's account;
(c) A complete history of all modifications to the rule parameters since implementation, including the date of each modification, the parameter(s) changed, the prior setting, the new setting, and the identity of the user who made the modification;
(d) Any property-level or department-level variations in the rule configuration (i.e., whether the rule is applied uniformly across all seven At-Issue Properties and all departments, or whether different parameters apply to certain properties or departments);
(e) System configuration screenshots or exports showing the rule as currently set and, to the extent available, historical configuration snapshots;
(f) Documentation of the exception or override process — specifically, the mechanism by which an employee or manager can reverse, adjust, or override an automatic meal-break deduction when an employee works through a meal period or when a meal break is interrupted, including the system workflow, required approvals, and any time limits for submitting exceptions; and
(g) Any Luminos user guides, help-desk articles, configuration guides, or implementation notes provided to VHG regarding the setup, use, or management of the automatic meal-break deduction functionality.
This request is directed to Luminos. To the extent VHG possesses copies of configuration documentation or implementation correspondence related to the AR-MEAL-030 rule, VHG should produce those materials as well.
Request 1.4 — Time-Punch Edit and Override Logs [Luminos / VHG]
Produce complete logs of all edits, overrides, deletions, manual adjustments, or other modifications to employee time-punch records within the Luminos TimeTrack system for all hourly, non-exempt employees at each of the seven At-Issue Properties.
Date Range: January 1, 2022 through the present date.
For each edit or modification, the log should include, at a minimum:
(a) The employee ID and employee name whose record was modified;
(b) The property code and department code;
(c) The date of the time punch that was modified;
(d) The original value(s) of the data field(s) that were changed;
(e) The revised value(s) of the data field(s) after the modification;
(f) The identity (user ID and name) of the person making the edit;
(g) The timestamp of the edit (date and time);
(h) Any reason code, comment, or notation entered in connection with the edit; and
(i) Whether the edit was initiated by the employee, a supervisor/manager, or a payroll/HR administrator.
Request 1.5 — Time-Rounding Policies and Configuration [Luminos / VHG]
Produce documentation of any time-rounding rules applied by the Luminos TimeTrack system or by VHG to employee time-punch records, including the following:
(a) The rounding increment (e.g., five-minute, six-minute, seven-minute, or fifteen-minute rounding);
(b) The direction of rounding (nearest increment, always round down, always round up, or other);
(c) Any property-level or department-level variations in rounding rules;
(d) The effective date(s) of each rounding rule and any changes to rounding rules during the Relevant Period; and
(e) The system configuration documentation (from Luminos) implementing the rounding rules.
In addition, produce all written policies, memoranda, or internal communications issued by VHG to managers, supervisors, or payroll personnel regarding time-rounding practices, including any guidance on the permissibility of rounding under the FLSA.
Request 1.6 — Scheduling Records [VHG]
Produce employee work schedules (i.e., posted or published schedules showing scheduled shifts) for all hourly, non-exempt employees at each of the seven At-Issue Properties.
Date Range: January 1, 2021 through the present date.
In connection with this request, VHG should identify the scheduling system or tool used at each property (e.g., a scheduling module within Luminos TimeTrack, a standalone scheduling application, or manual scheduling via spreadsheets or printed templates) and the format in which scheduling records are maintained. If scheduling was performed using different systems at different properties or at different times during the Relevant Period, identify each system and the applicable period.
CATEGORY 2: PAYROLL RECORDS AND WAGE STATEMENTS [PRIORITY]
Category 2 requests address payroll records, wage statements, and compensation data that are necessary to analyze overtime calculations, regular-rate determinations, and tip-credit compliance. Like Category 1, Category 2 is designated as a Priority category, and VHG and Luminos are requested to prioritize production of these items by February 10, 2026.
Request 2.1 — Payroll Registers [Luminos / VHG]
Produce complete payroll registers for all seven At-Issue Properties for every pay period within the Relevant Period.
Date Range: January 1, 2021 through the present date. For the period January 1, 2021 through December 31, 2021, produce payroll registers from VHG's prior payroll system or processor. For the period January 1, 2022 through the present date, produce payroll registers from the Luminos system.
For each pay period, the payroll register should show, at a minimum, the following information for each employee:
(a) Employee name and employee ID;
(b) Property code;
(c) Department code;
(d) Job code and job title;
(e) Pay rate (hourly rate, and, for tipped employees, the direct cash wage rate);
(f) Regular hours worked;
(g) Overtime hours worked;
(h) Regular pay;
(i) Overtime pay;
(j) Gross pay;
(k) Tip amounts reported or allocated (where applicable);
(l) Tip-credit amounts applied (where applicable);
(m) All deductions (itemized by category, including taxes, benefits, and any other deductions);
(n) Net pay;
(o) Any adjustments, retro-pay, or corrections applied; and
(p) Pay period start and end dates.
Format: .csv or Excel workbook, with column headers clearly identifying all fields.
Request 2.2 — Individual Employee Wage Statements / Pay Stubs [Luminos / VHG]
Produce sample wage statements (pay stubs) for each of the seven At-Issue Properties for a representative selection of pay periods across the Relevant Period. For initial purposes, and pending the development of a more refined sampling methodology in consultation with Ridgepoint Advisory Group LLC once engaged, produce wage statements for all employees at each At-Issue Property for the following periods:
•  Q1 2023 (all pay periods from January 1, 2023 through March 31, 2023);
•  Q1 2024 (all pay periods from January 1, 2024 through March 31, 2024); and
•  Q1 2025 (all pay periods from January 1, 2025 through March 31, 2025).
Each wage statement should include all fields shown to the employee, including but not limited to: hours worked (regular and overtime), pay rate(s), earnings (by category), deductions (itemized), net pay, tip amounts, tip credits, and cumulative year-to-date totals.
Calderwood & Harkness reserves the right to request additional pay-stub samples for other time periods or subsets of employees as the Audit progresses.
Request 2.3 — Overtime Calculation Methodology Documentation [Luminos / VHG]
Produce all documentation describing the algorithm, method, or configuration used by the Luminos TimeTrack system and/or VHG to calculate overtime pay, including the following:
(a) The definition of the workweek for FLSA overtime purposes, including the designated start day and start time of the workweek, and whether the workweek definition is uniform across all seven At-Issue Properties or varies by property;
(b) The regular-rate-of-pay calculation methodology, including the treatment of the following components in the regular rate: non-discretionary bonuses, shift differentials, service charges, tip credits, and any other forms of remuneration;
(c) The overtime multiplier applied (i.e., confirmation that the multiplier is 1.5 times the regular rate for all hours worked in excess of 40 in a workweek);
(d) Any Luminos system-configuration documentation specifying the overtime-calculation parameters; and
(e) Any VHG internal policies, memoranda, or payroll-department procedures governing overtime calculations, including instructions to payroll staff regarding the inclusion or exclusion of specific pay components in the regular rate.
Request 2.4 — Employee Compensation Records [VHG]
Produce, from VHG's HRIS (Human Resources Information System), a comprehensive dataset for all current and former non-exempt hourly employees at the seven At-Issue Properties who were employed at any time during the Relevant Period (January 1, 2021 through the present date), including the following data fields for each employee:
(a) Employee ID;
(b) Employee name (last, first, middle initial);
(c) Hire date;
(d) Separation date (if applicable) and reason for separation;
(e) Job title;
(f) Job code;
(g) Department;
(h) Property assignment(s) (including any transfers between properties, with effective dates);
(i) Complete pay-rate history, including all rate changes with effective dates;
(j) Exempt/non-exempt classification (and any changes to classification with effective dates);
(k) Full-time/part-time status (and any changes with effective dates); and
(l) Tipped/non-tipped designation (and any changes with effective dates).
Format: .csv or Excel workbook.
Request 2.5 — W-2 Forms and Annual Earnings Summaries [VHG]
Produce W-2 forms (IRS Form W-2, Wage and Tax Statement) or equivalent annual earnings summaries for all non-exempt hourly employees at the seven At-Issue Properties for each of the following tax years: 2021, 2022, 2023, 2024, and 2025. If W-2 forms for tax year 2025 have not yet been issued as of the date of production, produce the most current year-to-date earnings data available for 2025, and supplement with the final W-2 forms when issued.
Production may be in the form of electronic copies of the W-2 data in .csv or Excel format (rather than individual PDF images of each W-2 form), provided all fields are included.
CATEGORY 3: EMPLOYEE HANDBOOKS, POLICIES, AND PROCEDURES
Category 3 requests address written policies, handbooks, and training materials that will be used to evaluate VHG's stated practices regarding meal breaks, overtime, timekeeping, tip credits, and other matters at issue in the demand letter.
Request 3.1 — Employee Handbooks [VHG]
Produce all versions of the VHG Employee Handbook that were in effect at any time during the Relevant Period (January 1, 2021 through the present date), including the current version (identified by Calderwood & Harkness as version 7.2, with an effective date of January 1, 2025) and all prior versions.
For each version, identify the effective date and the date (if any) on which the version was superseded by a subsequent version. In addition, produce any property-specific handbook supplements, addenda, or amendments applicable to individual At-Issue Properties, if any. If certain policies differ by property (e.g., due to differences in applicable local ordinances or operational practices), identify those variations.
Request 3.2 — Meal-Break and Rest-Break Policies [VHG]
Produce all written policies, memoranda, bulletins, standard operating procedures, training materials, and other documents regarding meal breaks and rest breaks applicable to hourly, non-exempt employees at the seven At-Issue Properties, including the following:
(a) Duration requirements for meal breaks and rest breaks;
(b) Whether breaks are designated as paid or unpaid;
(c) Any on-call requirements or restrictions during meal breaks (e.g., whether employees are required to remain on the premises, carry a radio or phone, or respond to guest requests during their meal break);
(d) The process for employees to report missed, shortened, or interrupted meal breaks, including any forms, system entries, or notifications required;
(e) Any property-level or department-level variations in break policies (e.g., different policies for front-of-house vs. back-of-house employees, or different policies for high-season vs. low-season staffing);
(f) Any policies specifically governing the automatic meal-break deduction applied by the Luminos TimeTrack system, including the exception or correction process for employees who work through a meal break; and
(g) Any communications to employees or managers regarding changes to meal-break or rest-break policies during the Relevant Period.
Request 3.3 — Overtime Authorization Policies [VHG]
Produce all written policies, memoranda, and procedural documents regarding overtime authorization at the seven At-Issue Properties, including:
(a) Pre-approval requirements for overtime work (e.g., whether employees must obtain prior written or verbal authorization from a supervisor before working overtime);
(b) Manager sign-off or approval procedures for overtime recorded in the timekeeping system;
(c) Consequences or disciplinary measures for employees who work unauthorized overtime; and
(d) Any property-level or department-level variations in overtime-authorization procedures.
Calderwood & Harkness notes that overtime-authorization policies, while relevant, do not relieve an employer of the obligation to pay for overtime actually worked. However, the existence and enforcement of such policies may be relevant to the willfulness analysis under 29 U.S.C. § 255(a).
Request 3.4 — Uniform and Dress-Code Policies / Donning and Doffing Procedures [VHG]
Produce all written policies, standard operating procedures, and training materials regarding uniforms, dress codes, personal protective equipment ("PPE"), and any requirements for employees to don (put on) or doff (remove) uniforms, PPE, or other required work attire at the worksite, including:
(a) A description of the uniform or dress-code requirements for each hourly position at each At-Issue Property;
(b) Whether uniforms are stored on-site (e.g., in employee lockers or uniform rooms) or taken home by employees;
(c) Whether employees are required to arrive at work in uniform or to change into uniform after arriving at the property;
(d) Any time estimates for the donning and doffing process, whether generated by VHG or by a time-and-motion study;
(e) Any policies addressing whether donning and doffing time is treated as compensable work time or as non-compensable time; and
(f) Any changes to uniform or donning/doffing policies during the Relevant Period.
Request 3.5 — Pre-Shift and Post-Shift Activity Policies [VHG]
Produce all written policies, procedures, standard operating procedures, training materials, and communications addressing pre-shift and post-shift activities performed by hourly, non-exempt employees at the seven At-Issue Properties, including:
(a) Pre-shift activities such as booting up computer systems, reviewing guest-services logs, reviewing daily briefing materials, attending shift-handover briefings, setting up workstations, retrieving supplies, and similar activities;
(b) Post-shift activities such as system logout, completing end-of-shift reports, attending shift-handover briefings, securing equipment, returning supplies, and similar activities;
(c) Any guidance provided to managers or employees regarding when the workday begins and ends for timekeeping purposes — specifically, whether employees are instructed to clock in before or after completing pre-shift activities, and whether employees are instructed to clock out before or after completing post-shift activities; and
(d) Any communications from VHG management to property-level managers or employees regarding off-the-clock work, including any reminders that all work time must be recorded.
Request 3.6 — Tip-Pool Policies and Procedures [VHG]
Produce all written policies, procedures, and documentation governing tip pooling, tip sharing, or tip distribution at each of the seven At-Issue Properties, including:
(a) Identification of which job positions at each property participate in the tip pool and which positions are excluded;
(b) The formula, methodology, or allocation percentage used for tip distribution;
(c) Notice requirements provided to employees regarding the tip pool, including any written acknowledgments signed by employees;
(d) Records of any changes to tip-pool policies, formulas, or participating positions during the Relevant Period;
(e) Any policies addressing the FLSA tip-credit requirements under 29 U.S.C. § 203(m), including VHG's compliance with the requirement that no part of the tip credit may be retained by the employer and that tip-pool participants must be limited to employees who customarily and regularly receive tips; and
(f) Any policies addressing the Florida constitutional minimum-wage tip-credit provisions under Article X, Section 24 of the Florida Constitution.
Request 3.7 — Timekeeping Policies [VHG]
Produce all written policies, procedures, and training materials regarding employee timekeeping obligations, including:
(a) Instructions for clocking in and out using the Luminos TimeTrack system (or any predecessor system);
(b) Rules regarding when employees should clock in relative to the start of their scheduled shift and when they should clock out relative to the end of their scheduled shift;
(c) Consequences or disciplinary measures for failure to punch in or out, for buddy-punching, or for other timekeeping violations;
(d) Manager review and approval procedures for employee timesheets, including the frequency of review and the deadline for manager approval;
(e) Written rounding policies communicated to employees; and
(f) Any communications to employees or managers regarding changes to timekeeping policies or procedures during the Relevant Period.
CATEGORY 4: JOB DESCRIPTIONS AND EXEMPTION CLASSIFICATION DOCUMENTATION
Category 4 requests address the misclassification allegation in the demand letter. The Claimant alleges that certain "lead" and "senior" hourly positions were improperly classified as exempt under the FLSA administrative exemption.
Request 4.1 — Job Descriptions [VHG]
Produce all job descriptions for hourly, non-exempt positions at the seven At-Issue Properties, including but not limited to the following positions:
•  Front-desk associate
•  Front-desk lead
•  Concierge
•  Housekeeper
•  Housekeeping lead
•  Housekeeping supervisor
•  Maintenance technician
•  Maintenance lead
•  Food & beverage server
•  Banquet server
•  Bartender
•  Bellhop
•  Valet
•  Spa attendant
•  Pool attendant
•  Night auditor
•  Guest services representative
•  Any other "lead" or "senior" variants of these or other hourly positions
For each position, produce all versions of the job description in effect during the Relevant Period, with effective dates noted. If job descriptions were updated or revised during the Relevant Period, produce each version.
Request 4.2 — "Lead" and "Senior" Hourly Role Documentation [VHG]
Produce specific documentation for all positions bearing "lead" or "senior" designations that are or were classified as exempt under the FLSA administrative exemption (29 C.F.R. Part 541) at any time during the Relevant Period, including:
(a) The job description and duties statement for each such position;
(b) The salary or wage rate for each such position, including the pay history;
(c) The basis for the exemption classification, including any analysis of the salary-basis test (29 C.F.R. § 541.602) and the duties test (29 C.F.R. § 541.200);
(d) Any internal memoranda, legal opinions, or outside counsel advice supporting the classification;
(e) A current roster of all employees in such positions at each At-Issue Property, including employee ID, name, property, department, current pay rate, and date of appointment to the lead or senior role; and
(f) Any records of reclassification of lead or senior positions from exempt to non-exempt (or from non-exempt to exempt) during the Relevant Period, including the effective date and reason for the reclassification.
Request 4.3 — FLSA Exemption Classification Records [VHG]
Produce any internal analyses, memoranda, legal opinions, classification worksheets, or other documentation used by VHG to determine whether specific positions qualify for FLSA exemptions under 29 C.F.R. Part 541, including the administrative exemption (29 C.F.R. § 541.200), the executive exemption (29 C.F.R. § 541.100), and the professional exemption (29 C.F.R. § 541.300).
In addition, produce records of any reclassifications of positions from exempt to non-exempt or from non-exempt to exempt during the Relevant Period, including the position title, the prior classification, the new classification, the effective date, and the reason for the reclassification.
Request 4.4 — Organizational Charts [VHG]
Produce organizational charts for each of the seven At-Issue Properties showing reporting structures, department organization, and the placement of all hourly and salaried positions, including lead and senior roles within each department. Produce the current organizational chart for each property and any historical versions from the Relevant Period, if available.
If VHG does not maintain formal organizational charts, produce any equivalent documentation (e.g., staffing plans, reporting-structure memoranda, or HRIS-generated reports) reflecting the organizational hierarchy.
CATEGORY 5: TIP-CREDIT AND TIPPED-EMPLOYEE RECORDS
Category 5 requests address the tip-credit compliance allegations in the demand letter, which assert that VHG failed to satisfy the notice requirements for the tip credit under both the FLSA and the Florida Constitution and failed to ensure that tipped employees received the full minimum wage.
Request 5.1 — Tip-Credit Notices to Employees [VHG]
Produce all written notices provided to employees regarding VHG's use of the tip credit under FLSA § 203(m) and Article X, Section 24 of the Florida Constitution, including notices that set forth:
(a) The direct (cash) wage paid to the tipped employee by VHG;
(b) The amount claimed by VHG as a tip credit (which, as of September 30, 2025, was $3.02 per hour under Florida law);
(c) The additional amount by way of tips necessary to equal the full applicable minimum wage (which, as of September 30, 2025, was $14.00 per hour, with a tipped minimum wage of $10.98 per hour); and
(d) Any statement that all tips received by the employee must be retained by the employee except for a valid tip-pooling arrangement.
In addition, produce signed acknowledgments by employees confirming receipt of the tip-credit notice, if any such acknowledgments exist. Organize the acknowledgments by property and by time period.
Request 5.2 — Tip Records and Tip Distribution Logs [VHG]
Produce all records of tips received by employees at the seven At-Issue Properties, including:
(a) Individual tip declarations or tip reports submitted by employees (whether on paper or electronically);
(b) Tip-pool collection records, showing the aggregate tips collected for each department, shift, or tip-pool unit;
(c) Tip distribution calculations, showing how collected tips were allocated among participating employees; and
(d) Records of any tip credits applied to employee wages, including the per-hour tip-credit amount and the resulting direct wage paid.
Date Range: January 1, 2021 through the present date.
Request 5.3 — Identification of Tipped Positions [VHG]
Produce a list of all job positions at each of the seven At-Issue Properties for which VHG claims a tip credit, including the following information for each position:
(a) Job title and job code;
(b) Property;
(c) The direct cash wage paid to employees in the position;
(d) The tip-credit amount claimed;
(e) The applicable full minimum wage; and
(f) The time period during which the foregoing rates applied (reflecting any changes in minimum-wage rates during the Relevant Period, including the annual adjustments under the Florida constitutional minimum-wage provision).
CATEGORY 6: INTERNAL AUDIT AND COMPLIANCE RECORDS
Category 6 requests address VHG's internal compliance monitoring and its history of interaction with regulatory agencies regarding wage-and-hour matters. These records are relevant to the willfulness analysis, the assessment of VHG's good-faith defense under 29 U.S.C. § 259, and the identification of any pre-existing compliance issues.
Request 6.1 — Internal Audit Reports [VHG]
Produce all internal audit reports, compliance reviews, self-assessment reports, or similar documents relating to wage-and-hour compliance, payroll practices, timekeeping accuracy, overtime calculations, meal-break practices, or tip-credit compliance, prepared by or on behalf of VHG's internal audit function, HR department, legal department, or any outside consultant (other than Calderwood & Harkness) at any time during the Relevant Period.
This request includes, without limitation:
(a) Reports prepared by VHG's internal audit team;
(b) Compliance assessments prepared by outside HR consultants or employment-law advisors;
(c) Payroll-accuracy audits or spot-check reports; and
(d) Any corrective-action plans, remediation plans, or follow-up reports issued in response to findings from such audits or assessments.
Request 6.2 — DOL or State Agency Correspondence [VHG]
Produce all correspondence, notices, filings, and communications with the U.S. Department of Labor (Wage and Hour Division), the Florida Department of Economic Opportunity, or any other governmental agency regarding wage-and-hour compliance, investigations, audits, complaints, or enforcement actions involving VHG or any of the seven At-Issue Properties at any time during the Relevant Period.
This request includes, without limitation:
(a) Investigation notices and correspondence;
(b) Information requests and subpoenas from governmental agencies;
(c) VHG's responses to agency inquiries;
(d) Consent orders, compliance agreements, or settlement agreements;
(e) Corrective-action plans;
(f) Back-wage payment records resulting from agency investigations; and
(g) Records of any findings of violation or compliance determinations.
Request 6.3 — Prior Employee Complaints [VHG]
Produce records of all internal complaints, grievances, hotline reports, exit-interview comments, or other communications from employees (current or former) at the seven At-Issue Properties regarding unpaid wages, overtime violations, meal-break violations, off-the-clock work, tip-pool issues, tip-credit violations, or misclassification at any time during the Relevant Period.
For each complaint, produce records of VHG's investigation of and response to the complaint, including investigative notes, findings, corrective actions taken, and any follow-up communications with the complainant.
Request 6.4 — Payroll Reconciliation and Exception Reports [Luminos / VHG]
Produce all payroll exception reports, error logs, reconciliation reports, and variance reports generated by the Luminos TimeTrack system or by VHG's payroll department at any time during the Relevant Period, including:
(a) Reports identifying discrepancies between scheduled hours and actual hours worked;
(b) Missed-punch reports;
(c) Meal-break exception reports (identifying instances where the automatic meal-break deduction was applied but an exception was flagged or where an employee did not take a recorded meal break);
(d) Overtime alerts or overtime-threshold reports;
(e) Payroll reconciliation reports comparing time-punch data to payroll-register data; and
(f) Any similar reports used by VHG's payroll department to identify and resolve timekeeping or payroll discrepancies.
CATEGORY 7: HOTEL MANAGEMENT AGREEMENT AND JOINT-EMPLOYER RECORDS (VERIMARK SHORES CLEARWATER / PALOMAR REALTY PARTNERS LLC)
Category 7 requests address the relationship between VHG and Palomar Realty Partners LLC with respect to the Verimark Shores Clearwater property. Because VHG manages this property under a Hotel Management Agreement but does not own it, the question of whether Palomar Realty Partners LLC may be a joint employer — and, conversely, whether VHG's potential liability exposure includes or excludes Clearwater employees — requires analysis of the management agreement and the parties' operational roles.
Request 7.1 — Hotel Management Agreement [VHG]
Produce the Hotel Management Agreement between VHG and Palomar Realty Partners LLC dated June 1, 2021 (reference: HMA-2021-0601-PC), together with all amendments, addenda, side letters, and any related agreements.
Calderwood & Harkness requests particular attention to the following provisions:
(a) Provisions addressing VHG's authority over employment decisions, including hiring, firing, discipline, promotion, and compensation of employees at the Verimark Shores Clearwater property;
(b) Provisions allocating payroll costs between VHG and Palomar Realty Partners LLC;
(c) Provisions addressing Palomar's role (if any) in directing day-to-day operations or labor-management decisions at the property;
(d) Indemnification and hold-harmless provisions, including any allocation of liability for employment-related claims; and
(e) Insurance requirements and additional-insured designations.
Request 7.2 — Palomar-Related Correspondence [VHG]
Produce all correspondence between VHG and Palomar Realty Partners LLC (including its Managing Member, Ricardo E. Montalvo) or its representatives regarding staffing, compensation, payroll, or labor compliance at the Verimark Shores Clearwater property.
Date Range: June 1, 2021 (the effective date of the Hotel Management Agreement) through the present date.
This request includes, without limitation, correspondence regarding staffing levels, wage rates, employee benefits, overtime costs, compliance with wage-and-hour laws, and any complaints or claims by employees at the Clearwater property.
CATEGORY 8: ELECTRONIC COMMUNICATIONS
Category 8 requests address email and messaging records that may contain evidence relevant to the five categories of allegations, including manager-level awareness of compliance issues, instructions regarding off-the-clock work, and communications with or about the Claimant.
Request 8.1 — Email and Messaging Records [VHG]
Produce email communications from the files of the twenty-three (23) identified custodians that are responsive to a keyword search using terms related to the subject matter of the Audit. The preliminary keyword list includes the following terms (a final, expanded search-term list will be provided separately to Mr. Jefferson):
overtime, meal break, meal-break, auto-deduction, auto deduction, timekeeping, punch, clock-in, clock-out, clock in, clock out, uniform, donning, doffing, tip pool, tip-pool, tip credit, tip-credit, minimum wage, FLSA, Fair Labor Standards, off-the-clock, off the clock, pre-shift, post-shift, pre shift, post shift, exempt, non-exempt, nonexempt, classification, misclassif, reclassif, Luminos, TimeTrack, Serrano, Garza, demand letter, wage complaint, unpaid wage*, wage-and-hour, wage and hour, AR-MEAL-030
Date Range: January 1, 2021 through the present date.
This request encompasses:
(a) Corporate email (VHG-issued email accounts);
(b) Personal email accounts used for business purposes, to the extent identifiable and within the custodians' possession, custody, or control; and
(c) Internal messaging platforms used by VHG, including but not limited to Meridian Solutions, Northgate Data Systems, or any other enterprise-messaging application.
Collection and preservation of email should be coordinated with Malik P. Jefferson, Corporate IT Administrator. Mr. Jefferson should ensure that litigation-hold protocols have been implemented for all twenty-three custodians and that auto-deletion or archival-purge functions have been suspended for the affected mailboxes and messaging accounts.
Request 8.2 — Text Messages and Instant Messages [VHG]
Produce any text messages (SMS, Westmark Software, or similar) or instant messages exchanged between managers or supervisors and hourly employees at the seven At-Issue Properties regarding scheduling, shift coverage, overtime, meal breaks, timekeeping, or any of the subject-matter areas identified in this Request List, to the extent such messages are available and within the identified custodians' possession, custody, or control.
Calderwood & Harkness recognizes that text messages may be more difficult to collect and preserve than corporate email. Accordingly, VHG should, at a minimum, issue a supplemental litigation-hold notice to all identified custodians instructing them to preserve text messages and personal-device messages related to the subject matter of the Audit. If forensic imaging of mobile devices is required, Calderwood & Harkness will coordinate with VHG's IT department and, if necessary, engage a third-party forensic vendor.
CATEGORY 9: INSURANCE RECORDS
Category 9 requests address VHG's Employment Practices Liability ("EPL") insurance coverage, which may be implicated in the event of litigation arising from the demand letter.
Request 9.1 — EPL Insurance Policy [VHG]
Produce the complete Employment Practices Liability insurance policy issued by Pinnacle Indemnity Corp. to VHG, including:
(a) Current Policy: Policy No. PIN-EPL-2025-44781, with a policy period of July 1, 2025 through June 30, 2026, including all endorsements, exclusions, conditions, and declarations pages;
(b) Prior-Year Policies: All EPL insurance policies (or renewal certificates and endorsement schedules, if full policies are not available) in effect at any time during the Relevant Period (January 1, 2021 through the present); and
(c) Coverage Summary: Calderwood & Harkness understands that the current policy provides coverage limits of $10,000,000 per occurrence and $25,000,000 in the aggregate, with a self-insured retention ("SIR") of $500,000 per claim. Please confirm these coverage parameters and produce documentation supporting them. This information is required for the coverage analysis that Calderwood & Harkness will prepare as part of the preliminary exposure assessment.
Request 9.2 — Prior Claims History [VHG]
Produce records of any prior claims tendered by VHG under its EPL insurance policies related to wage-and-hour disputes, employment classification disputes, tip-credit disputes, or similar employment-related matters at any time during the Relevant Period. Include the claim number, date of claim, nature of the underlying dispute, outcome (if resolved), and any amounts paid by the insurer or by VHG under the SIR.
CATEGORY 10: MISCELLANEOUS
Category 10 includes additional requests that do not fall neatly within the categories above but are necessary for the Audit.
Request 10.1 — Training Materials [VHG]
Produce all training materials provided to managers, supervisors, and hourly employees at the seven At-Issue Properties regarding the following subjects:
(a) Timekeeping procedures and use of the Luminos TimeTrack system;
(b) Overtime management and authorization;
(c) Meal-break and rest-break compliance;
(d) Wage-and-hour law (federal and Florida state);
(e) Tip-pool administration and tip-credit compliance; and
(f) Employee classification under the FLSA.
For each training program or session, produce sign-in sheets, electronic attendance records, or other documentation reflecting which managers or employees participated and the date(s) of the training.
Request 10.2 — Arbitration and Dispute-Resolution Agreements [VHG]
Produce all arbitration agreements, class-action waiver agreements, collective-action waiver agreements, or alternative dispute-resolution ("ADR") agreements signed by employees at the seven At-Issue Properties during the Relevant Period, including:
(a) Standalone arbitration agreements;
(b) ADR provisions contained in the VHG Employee Handbook;
(c) ADR provisions contained in offer letters or employment agreements; and
(d) Any acknowledgment forms signed by employees confirming their agreement to the ADR provisions.
In addition, produce records (e.g., a spreadsheet or HRIS report) identifying which employees at the At-Issue Properties signed an arbitration or ADR agreement and which did not, including the date of signature. This information is critical to assessing VHG's ability to compel individual arbitration and to defeat any collective-action certification.
Request 10.3 — Claimant-Specific Records — Daniela M. Serrano [VHG]
Produce the complete personnel file for the Claimant, Daniela M. Serrano (Employee ID: VHG-EMP-20220314-5587), including all of the following:
(a) Employment application;
(b) Offer letter or employment agreement;
(c) Signed employee-handbook acknowledgment(s);
(d) Signed arbitration or ADR agreement(s);
(e) Signed tip-credit notice(s);
(f) I-9 form and supporting documentation;
(g) W-4 forms and any amendments;
(h) Performance reviews and evaluations;
(i) Disciplinary records, including written warnings and corrective-action notices;
(j) Separation documentation, including any resignation letter, termination notice, or separation agreement;
(k) Exit-interview records or forms; and
(l) Any other documents contained in Ms. Serrano's personnel file.
Relevant employment details for the Claimant are as follows:
•  Hire Date: March 14, 2022
•  Separation Date: August 22, 2025
•  Position: Front-Desk Associate (hourly, non-exempt)
•  Primary Work Location: Verimark Regency Tampa
In addition to the personnel file, produce all timekeeping records (time-punch data from both the pre-Luminos and Luminos systems, to the extent applicable), pay stubs, payroll register entries, and tip records for Ms. Serrano for her entire tenure of employment (March 14, 2022 through August 22, 2025).
Request 10.4 — Luminos Payroll Solutions Inc. — Service Agreement [VHG]
Produce the master services agreement (or equivalent contract) between VHG and Luminos Payroll Solutions Inc. governing payroll processing and timekeeping services, effective January 1, 2022, together with all amendments, statements of work, service-level agreements, and schedules.
Calderwood & Harkness requests particular attention to the following provisions:
(a) Data ownership — which party owns the timekeeping and payroll data processed through the Luminos system;
(b) Data retention and destruction policies — how long Luminos retains VHG's data after termination or expiration of the agreement, and under what circumstances data may be deleted or archived;
(c) System configuration responsibilities — which party (VHG or Luminos) is responsible for configuring the auto-deduction rules, rounding rules, overtime-calculation algorithms, and other system parameters;
(d) Indemnification provisions — including any allocation of liability for errors in payroll processing or timekeeping;
(e) Cooperation obligations — including any obligations on Luminos to cooperate with VHG in connection with audits, investigations, or litigation; and
(f) Data-export capabilities — including VHG's ability to export data in native format through its administrative portal.
Request 10.5 — Hargrove Kessler & Co. LLP Audit Workpapers (Wage-Related) [VHG]
To the extent available and not subject to accountant-client privilege limitations under applicable Florida law, produce any workpapers, schedules, or communications from Hargrove Kessler & Co. LLP (Engagement Partner: Nathaniel R. Webb, CPA) relating to VHG's payroll accruals, wage-and-hour contingency disclosures, or employee-benefit obligations in connection with the following annual audits:
•  FY 2023 (fiscal year ended December 31, 2023);
•  FY 2024 (fiscal year ended December 31, 2024); and
•  FY 2025 (fiscal year ended December 31, 2025, to the extent the audit is complete or in progress).
Calderwood & Harkness is particularly interested in any contingency disclosures or footnotes relating to potential wage-and-hour liabilities, any management representation letters addressing employment-law compliance, and any communications between Hargrove Kessler and VHG management regarding payroll-related audit findings. VHG should consult with its General Counsel regarding the scope of any accountant-client privilege before producing these materials.
Request 10.6 — Board and Audit Committee Minutes [VHG]
Produce minutes of VHG Board of Directors and Audit Committee meetings at which any of the following topics were discussed:
(a) Wage-and-hour compliance;
(b) Employee litigation or potential employee litigation;
(c) The demand letter from Garza, Linden & Okafor LLP dated January 14, 2026;
(d) The engagement of Calderwood & Harkness LLP for the pre-litigation Audit; or
(e) Any related employment-risk management topics.
This request specifically includes the minutes of the January 29, 2026 Audit Committee meeting at which the Audit Committee authorized the engagement of Calderwood & Harkness LLP for the pre-litigation wage-and-hour audit at an approved budget of up to $350,000.
Calderwood & Harkness recognizes that Board and Audit Committee minutes may contain discussions of other confidential matters unrelated to the Audit. VHG may redact portions of the minutes that are unrelated to the topics identified above, provided that the redactions are noted and a privilege log entry is made if the redacted content is withheld on the basis of a privilege other than relevance.
IV. PRODUCTION TRACKING AND CONTACT INFORMATION
A. Production Log
VHG and Luminos should maintain a detailed production log for all documents and data produced in response to this Request List. The production log should include, for each production:
(a) The date of production;
(b) The Request List category and request number to which the production is responsive;
(c) A brief description of the documents or data produced;
(d) The volume of the production (number of documents, number of pages, number of electronic files, or data-file size, as applicable);
(e) The custodian(s) from whom the documents were collected;
(f) The format of the production (e.g., .csv, .xlsx, .pdf, .pst); and
(g) Any notes regarding completeness, pending follow-up items, or known gaps.
Calderwood & Harkness will provide VHG with a shared tracking spreadsheet in Excel format to facilitate consistent logging across all production sources. The tracking spreadsheet will be distributed to Mr. Fuentes and Ms. Whitfield within two (2) business days of the date of this Request List.
B. Points of Contact
The following individuals are designated as points of contact for purposes of coordinating the collection and production of documents and data:
VHG Internal Coordinator:
Enrique J. Fuentes Director, Payroll & Workforce Compliance Verimark Hospitality Group Inc. 2400 Bayshore Boulevard, Suite 1100 Tampa, FL 33629
Mr. Fuentes will serve as th