Dear Ms. Prewitt,
My name is James Underwood, and I am an associate at Calderwood & Harkness LLP, located at 100 Southeast Second Street, Suite 3400, Miami, FL 33131. Our firm represents Verimark Hospitality Group Inc. ("VHG") in connection with a pending employment matter (firm matter number 1021-00005). I am writing to you in your capacity as Senior Account Manager at Luminos Payroll Solutions Inc. ("Luminos") responsible for the VHG account.
Copied on this email is Enrique J. Fuentes, VHG's Director of Payroll & Workforce Compliance, who has authorized Calderwood & Harkness to communicate directly with Luminos regarding the request described below.
**Purpose of This Email**
Please find attached a formal data preservation request letter on Calderwood & Harkness letterhead (luminos-data-preservation-letter.docx), which I am transmitting on behalf of VHG. VHG has received a demand raising wage-and-hour allegations. In connection with VHG's obligations to preserve all relevant documents and electronically stored information, VHG and its counsel are requesting that Luminos immediately preserve all data associated with VHG's account and refrain from any deletion, modification, or destruction of such data.
**Specific Data and Systems to Be Preserved**
The request pertains to VHG's account under Luminos TimeTrack System ID **LTT-VHG-2022-0041**. We are requesting that Luminos preserve the following categories of data for the period from **January 1, 2022** (the date VHG transitioned its payroll operations to the Luminos platform) **through the present**:
1. **Time-Punch Records.** All clock-in/clock-out data for all VHG employees across all 14 properties, with particular attention to the seven properties identified in the attached letter: Verimark Regency Tampa, Verimark Grand Orlando, Verimark Shores Clearwater, Verimark Bayfront St. Petersburg, Verimark Resort & Spa Boca Raton, Verimark Oceanview Fort Lauderdale, and Verimark Key West Collection.
2. **Automatic Meal-Break Deduction Configuration.** The full configuration history for auto-deduction rule AR-MEAL-030 (the 30-minute automatic deduction applied to shifts of six or more hours), including any modifications, overrides, or exceptions logged in the system since implementation.
3. **Payroll Registers and Wage Statements.** All payroll processing records, pay-period registers, and individual wage statements generated through the Luminos platform for VHG employees.
4. **Overtime Calculation Algorithms and Settings.** Documentation or system records showing how overtime was calculated for VHG employees, including the regular-rate-of-pay computation methodology and any custom configurations applied to the VHG account.
5. **System-Audit Logs.** All audit trails, edit logs, and administrative-change logs for the VHG account reflecting any manual adjustments to time records, pay codes, deduction rules, or employee classifications.
6. **Scheduling Data.** Any shift-scheduling data maintained within the Luminos TimeTrack platform for VHG properties.
7. **Tip-Related Records.** Any records of tip amounts, tip-pool allocations, or tip-credit calculations processed through the Luminos system for VHG employees.
**Data Export Request**
In addition to preservation, we are requesting that Luminos prepare a comprehensive data export encompassing all of the above categories in a usable electronic format — preferably CSV or delimited text files, accompanied by data dictionaries and complete field definitions. The attached letter contains detailed specifications for the export format and scope.
The data export will be coordinated with Mr. Fuentes, and Calderwood & Harkness may engage a forensic payroll consultant to assist with analysis of the exported data. We will advise you if and when a third-party consultant is retained so that appropriate arrangements can be made.
**Request for Confirmation**
We respectfully ask that you confirm in writing, via reply to this email, **by no later than Friday, February 13, 2026**, the following:
1. That Luminos has received this preservation request and the attached letter; 2. That Luminos has implemented a litigation hold on all data responsive to this request for account LTT-VHG-2022-0041; and 3. That no data within the scope of this request will be deleted, overwritten, or modified pursuant to any routine data-retention or purge schedules.
If any of the data categories identified above are not available or may require additional time to retrieve, we would ask that you identify those categories in your response so that the parties can discuss alternatives promptly.
**Timeline and Availability**
The underlying matter involves time-sensitive deadlines, and we appreciate your prompt attention to this request. I would be happy to schedule a call at your convenience to discuss any questions you may have about the scope of the preservation request or the export specifications. You may reach me directly at the contact information below. Additionally, Nadia Petrov, lead associate on this matter, is available to assist and can be reached at npetrov@calderwoodharkness.com or (305) 982-6140.
Thank you very much for your cooperation and prompt attention to this matter. We look forward to hearing from you.
Best regards,
**James Underwood** Associate Calderwood & Harkness LLP 100 Southeast Second Street, Suite 3400 Miami, FL 33131 Direct: (305) 982-6217 Email: junderwood@calderwoodharkness.com
---
*CONFIDENTIALITY NOTICE: This email message and any attachments are intended solely for the use of the individual or entity to whom they are addressed and may contain information that is privileged, confidential, and exempt from disclosure under applicable law, including attorney-client privileged communications and attorney work product. If you are not the intended recipient, you are hereby notified that any dissemination, distribution, copying, or other use of this message or its attachments is strictly prohibited. If you have received this communication in error, please notify the sender immediately by reply email and permanently delete the original message and all copies. Thank you.*