1021-00005 · Verimark Hospitality Group · Preservation

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CALDERWOOD & HARKNESS LLP Attorneys at Law

100 Southeast Second Street, Suite 3400 Miami, Florida 33131

Telephone: (305) 884-7200 Facsimile: (305) 884-7201 www.calderwoodharkness.com

February 3, 2026

VIA EMAIL AND CERTIFIED MAIL RETURN RECEIPT REQUESTED

Devin K. Arroyo, Esq. General Counsel Verimark Hospitality Group Inc. 2400 Bayshore Boulevard, Suite 1100 Tampa, Florida 33629

Re: Litigation Hold Advisory — Preservation of Documents and Electronically Stored Information

Demand of Daniela M. Serrano; Garza, Linden & Okafor LLP Demand Letter dated January 14, 2026

Threatened FLSA Collective / Class Action — Wage-and-Hour Claims

Calderwood & Harkness Matter No. 1021-00005

Dear Mr. Arroyo:

I. Purpose and Background

I write in my capacity as Responsible Partner, Labor & Employment, at Calderwood & Harkness LLP, to provide Verimark Hospitality Group Inc. ("VHG" or "the Company") with formal outside counsel guidance regarding VHG's document- and data-preservation obligations arising from the threatened wage-and-hour litigation described herein. This letter is addressed to you in your capacity as General Counsel of VHG and is intended to be shared, as appropriate and in accordance with the privilege guidance set forth in Section X below, with the individuals and departments responsible for implementing and overseeing VHG's preservation efforts.

As you are aware, on or about January 14, 2026, Marco A. Garza of Garza, Linden & Okafor LLP ("GLO"), 600 Brickell Avenue, Suite 2200, Miami, Florida 33131, transmitted a demand letter on behalf of his client, Daniela M. Serrano (Employee ID VHG-EMP-20220314-5587), a former front-desk associate at the Verimark Regency Tampa property. Ms. Serrano was employed by VHG from March 14, 2022 through August 22, 2025. Your office received the GLO demand letter on January 16, 2026.

The GLO demand letter threatens to initiate a collective action under Section 16(b) of the Fair Labor Standards Act, 29 U.S.C. § 216(b), as well as a class action under the Florida Constitution, Article X, Section 24, alleging systemic wage-and-hour violations across seven Verimark-branded hotel and resort properties in the State of Florida. The demand letter identifies a putative collective and class consisting of all current and former hourly, non-exempt employees at the seven Verimark-branded properties in Florida from January 2023 to the present — a group estimated by GLO to encompass approximately 4,100 to 5,900 individuals. The demand letter claims damages of approximately $18.5 million, inclusive of back pay, liquidated damages, and attorneys' fees, and imposes a response deadline of February 28, 2026.

Calderwood & Harkness was engaged by VHG on January 30, 2026, following authorization by the VHG Audit Committee on January 29, 2026, to represent the Company in connection with the threatened litigation and to provide comprehensive legal counsel on all related matters, including preservation, pre-litigation strategy, and defense.

This letter supplements and is intended to formalize and strengthen VHG's internal litigation-hold memorandum issued by your office on January 17, 2026 — one day after receipt of the GLO demand letter. Your prompt action in issuing the internal hold was both appropriate and commendable. Nevertheless, based on our review of the scope of the threatened claims, the breadth of the putative collective and class, and the data systems and records implicated, Calderwood & Harkness has determined that additional specificity and formalization of VHG's preservation obligations is warranted. This letter provides that additional guidance.

The Company's obligation to preserve all relevant documents and electronically stored information ("ESI") arose no later than January 16, 2026, when your office received the GLO demand letter, thereby triggering a duty to preserve under both federal and Florida law. As detailed below, the scope of that obligation is broad and extends across multiple categories of documents, data systems, and custodians.

II. Legal Obligation to Preserve

The duty to preserve relevant evidence arises when a party knows or reasonably should know that litigation is likely. Here, VHG's duty to preserve was triggered no later than January 16, 2026, upon receipt of the GLO demand letter, which unambiguously threatened the commencement of a collective and class action in federal court. The receipt of that demand letter placed VHG on clear notice that litigation was reasonably anticipated, and preservation obligations attached at that time.

The legal consequences of failing to meet this obligation are significant. Under Federal Rule of Civil Procedure 37(e), if ESI that should have been preserved in the anticipation or conduct of litigation is lost because a party failed to take reasonable steps to preserve it, and the information cannot be restored or replaced through additional discovery, the court may order measures no greater than necessary to cure the prejudice — or, upon a finding of intent to deprive another party of the information's use, may presume the lost information was unfavorable to the party that failed to preserve it, instruct the jury that it may or must presume the information was unfavorable, or dismiss the action or enter a default judgment. Additionally, Federal Rule of Civil Procedure 26(g) imposes an affirmative obligation on parties and their counsel to certify that discovery responses are complete and accurate, which presupposes adequate preservation. Florida courts likewise recognize spoliation as a basis for adverse-inference instructions, sanctions, and, in egregious cases, independent tort liability.

The scope of VHG's preservation obligation extends to all documents and ESI that are relevant to, or reasonably likely to be relevant to, the claims and defenses in the anticipated litigation, including documents that may be relevant to damages calculations, class and collective certification, and affirmative defenses.

Given the nature and breadth of the allegations raised in the GLO demand letter, the preservation obligation is necessarily broad. The demand letter identifies five categories of substantive allegations:

1. Overtime violations under 29 U.S.C. § 207(a), including allegations that VHG failed to compensate hourly, non-exempt employees for all hours worked in excess of forty (40) hours in a workweek at a rate of not less than one and one-half times the employee's regular rate of pay;

2. Illegal automatic meal-break deductions, including allegations that VHG's timekeeping system automatically deducted thirty (30) minutes from employee time records for each shift of six (6) or more hours, regardless of whether the employee was actually relieved of all duties during the meal break;

3. Failure to compensate pre-shift and post-shift work, including allegations that VHG required hourly employees to perform compensable work activities — such as computer boot-up, system logins, shift-handover briefings, and uniform donning and doffing — before clocking in and after clocking out;

4. Florida tipped-employee minimum wage violations, including allegations that VHG failed to pay certain tipped employees the applicable Florida minimum wage, taking into account the tip credit claimed by VHG, and failed to provide adequate notice of the tip credit to affected employees as required under the FLSA and Florida law; and

5. Misclassification of "lead" and "senior" hourly roles under the FLSA administrative exemption, including allegations that VHG improperly classified certain positions designated as "lead" or "senior" as exempt from the FLSA's overtime requirements when such positions did not satisfy the duties test for the administrative exemption under 29 C.F.R. § 541.200.

The applicable statutes of limitations determine the temporal scope of VHG's preservation obligation. The relevant limitations periods are as follows:

• FLSA willful violations: Three-year lookback from the date of the demand letter, reaching back to January 14, 2023 (29 U.S.C. § 255(a));

• FLSA non-willful violations: Two-year lookback from the date of the demand letter, reaching back to January 14, 2024 (29 U.S.C. § 255(a)); and

• Florida constitutional minimum-wage claims: Five-year statute of limitations under Florida Statutes § 95.11(2)(b), reaching back to January 14, 2021.

In light of the foregoing, and to ensure that VHG's preservation efforts cover the longest applicable limitations period with a reasonable cushion, Calderwood & Harkness recommends that VHG preserve all relevant documents and ESI from January 1, 2021 to the present. This recommended preservation window encompasses the full five-year lookback for the Florida constitutional claims, with a two-week buffer to account for any potential disputes regarding the accrual date, as well as the shorter FLSA limitations periods.

III. Categories of Documents and ESI to Be Preserved

The following is a comprehensive, though not necessarily exhaustive, list of the categories of documents and ESI that must be preserved. VHG should preserve all documents and ESI falling within the categories described below for all seven at-issue properties (identified in Section VII) and for the preservation period of January 1, 2021 to the present, unless a different scope is specified below. If any VHG employee, manager, or officer becomes aware of additional categories of potentially relevant documents or data not identified below, that information should be brought to the attention of Calderwood & Harkness immediately.

A. Timekeeping and Punch Data

VHG must preserve all time-punch records, clock-in/clock-out data, and time entries from the Luminos TimeTrack platform (Account ID: LTT-VHG-2022-0041) for all hourly, non-exempt employees at each of the seven at-issue properties from January 2021 to the present. This encompasses the full universe of electronic timekeeping data maintained by VHG through Luminos Payroll Solutions Inc.

Additionally, VHG must preserve all timekeeping data from any prior timekeeping system used by VHG before the Company's transition to Luminos Payroll Solutions Inc. on January 1, 2022. To the extent that historical timekeeping data from such legacy systems has been migrated to Luminos TimeTrack or retained in a separate archive or database, all such data must be preserved intact.

VHG must also preserve all records of manual time adjustments, edits, overrides, or corrections made to time-punch records at any time during the preservation period, whether such adjustments were initiated by employees, supervisors, property-level HR managers, or payroll personnel. This includes records of the identity of the individual who made the adjustment, the date and time of the adjustment, the original and modified values, and any reason codes or notations associated with the adjustment.

All system-audit logs and change-history logs generated by Luminos TimeTrack, including logs that record user access, data modifications, configuration changes, and error events, must be preserved in their native format.

B. Payroll Records

VHG must preserve all payroll registers, pay stubs, wage statements, and earnings records for all non-exempt, hourly employees at the seven at-issue properties for the preservation period. This includes both electronic payroll records maintained by VHG and any records maintained by Luminos Payroll Solutions Inc. on VHG's behalf.

VHG must also preserve all records relating to overtime calculations, including the algorithms, formulas, and configuration settings used by Luminos Payroll Solutions Inc. to calculate overtime pay for VHG employees. This includes documentation of the regular rate of pay calculation methodology, including any adjustments made for tips, non-discretionary bonuses, shift differentials, or other forms of remuneration that are required to be included in the regular rate under the FLSA.

All records relating to Luminos Payroll Solutions Inc.'s processing of VHG's payroll must be preserved, including the master service agreement between VHG and Luminos Payroll Solutions Inc., all statements of work, configuration documentation, implementation records, change orders, and any correspondence regarding payroll processing errors, discrepancies, or compliance concerns.

C. Automatic Meal-Break Deduction Records

Given the centrality of the automatic meal-break deduction allegations to the threatened litigation, VHG must preserve with particular care all records relating to the automatic meal-break deduction configuration within Luminos TimeTrack — specifically, the auto-deduction rule designated as AR-MEAL-030, which is configured to automatically deduct thirty (30) minutes from an employee's recorded work time for each shift of six (6) or more hours.

VHG must preserve the complete configuration history for rule AR-MEAL-030, including the date the rule was initially implemented, any subsequent modifications, overrides, exceptions, or temporary suspensions of the rule, and the identity of any VHG or Luminos personnel who authorized or implemented such changes.

VHG must also preserve all records relating to any meal-break exception or correction process — that is, any procedure by which employees could report that they were not fully relieved of duties during an automatically deducted meal break and request a correction to their time records. This includes any forms, electronic submissions, supervisor approvals, or payroll adjustments associated with such corrections.

Additionally, all meal-break waivers, acknowledgment forms, sign-off sheets, or other documentation by which employees purportedly agreed to the automatic deduction or waived their right to a meal break must be preserved.

D. Scheduling Records

VHG must preserve all employee work schedules, shift assignments, and scheduling templates for each of the seven at-issue properties during the preservation period. This includes both electronic scheduling records and any paper-based scheduling documents, such as scheduling binders or posted schedules.

Records of schedule changes, shift swaps, on-call designations, and any other modifications to posted or electronic schedules must also be preserved. VHG should further preserve any records showing the comparison between scheduled shift start and end times and actual clock-in and clock-out times, as such records may be relevant to the pre-shift and post-shift work allegations.

E. Employee Handbooks, Policies, and Procedures

VHG must preserve all versions of the VHG employee handbook in effect at any time during the preservation period. This includes the current version (v.7.2, effective January 1, 2025) and all prior versions, drafts, and redlined revisions. To the extent that different versions of the handbook were in effect at different properties or at different times, all such versions must be preserved.

In addition to the employee handbook, VHG must preserve all standalone policies, procedures, standard operating procedures, training materials, and management directives relating to the following subjects:

• Meal-break and rest-break policies, including any policies governing the circumstances under which an employee may be required to remain on duty or on premises during a meal break;

• Overtime authorization and approval policies, including any policies requiring advance authorization for overtime work and any policies regarding the consequences of unauthorized overtime;

• Uniform and dress-code policies, including any donning and doffing requirements, grooming standards, or procedures requiring employees to change into or out of uniforms, safety equipment, or other attire on the employer's premises;

• Pre-shift and post-shift duty requirements, including any policies or practices relating to computer boot-up procedures, system logins, register preparation, shift-handover briefings, security checks, or other activities performed before or after an employee's scheduled shift;

• Tip-pool policies, tip-credit notices, and tip distribution records, including any written notices provided to tipped employees regarding the employer's use of a tip credit;

• Timekeeping policies, including policies governing clock-in and clock-out procedures, time-rounding rules, and the process for correcting timekeeping errors.

F. Job Descriptions and Classification Records

VHG must preserve all job descriptions for hourly, non-exempt positions at each of the seven at-issue properties, including any revisions to such job descriptions during the preservation period. This encompasses job descriptions for front-desk associates, concierge staff, housekeeping personnel, food and beverage workers, maintenance technicians, and all other hourly positions.

Of particular importance to the misclassification allegations, VHG must preserve all job descriptions and classification analyses for positions designated as "lead" or "senior" that are alleged to have been improperly classified as exempt under the FLSA administrative exemption. This includes any FLSA exemption classification worksheets, analyses, memoranda, or opinions prepared by VHG's in-house legal department, HR department, or any outside consultants or law firms. Any records of reclassification actions — that is, instances in which VHG changed the classification of a position from exempt to non-exempt or vice versa — must also be preserved, along with the reasons for such reclassification.

G. Tip-Pool and Tip-Credit Records

VHG must preserve all tip-pool distribution records for front-desk, concierge, valet, bellhop, and any other positions participating in tip pools at the seven at-issue properties during the preservation period. This includes records showing the total tips received, the methodology for distributing tips among participants, the amounts distributed to each participant, and any management involvement in the tip-pool process.

VHG must further preserve all tip-credit notices provided to tipped employees, whether in writing or electronically, including any acknowledgment forms signed by employees. Records showing the hourly cash wage paid to tipped employees — currently $10.98 per hour, based on the Florida tipped minimum wage of $14.00 per hour minus the $3.02 tip credit — must be preserved, along with any records showing historical changes to these rates during the preservation period. All records of total tips received and distributed to individual employees, including any records maintained by employees or supervisors, must be preserved.

H. Employment Records

VHG must preserve the complete personnel file for Daniela M. Serrano (Employee ID VHG-EMP-20220314-5587), including but not limited to her application, offer letter, employment agreement, performance evaluations, disciplinary records, compensation history, benefits enrollment, and separation documentation.

More broadly, VHG must preserve offer letters, employment agreements, and separation documents — including resignation letters, termination notices, and separation agreements — for all current and former hourly employees at the seven at-issue properties during the preservation period. Employment eligibility records, including I-9 forms, should be preserved to the extent they are relevant to establishing employment dates and eligibility.

VHG must also preserve all records of employee complaints, grievances, or inquiries relating to pay, overtime, meal breaks, timekeeping, tip distribution, or any other wage-and-hour topic, whether submitted formally through a grievance procedure, informally through conversations with supervisors or HR, or through any anonymous reporting mechanism.

I. Internal Audit and Compliance Records

VHG must preserve all internal audit reports, compliance reviews, risk assessments, and related work papers that address or relate to wage-and-hour compliance, payroll accuracy, timekeeping practices, or FLSA compliance at any of the seven at-issue properties during the preservation period. This includes reports prepared by or at the direction of the Director of Payroll & Workforce Compliance, Enrique J. Fuentes, as well as reports prepared by or at the direction of the Vice President of Human Resources, Carla S. Whitfield.

Any reports, memoranda, analyses, or presentations prepared by Mr. Fuentes, Ms. Whitfield, or their respective staffs regarding wage-and-hour issues, including gap analyses, remediation plans, or compliance roadmaps, must be preserved.

VHG must also preserve any correspondence with Luminos Payroll Solutions Inc. — including correspondence with Shannon D. Prewitt, Senior Account Manager — regarding payroll processing errors, configuration issues, system malfunctions, data discrepancies, or compliance concerns. This includes email correspondence, meeting notes, trouble tickets, and service-level reports.

All compliance training materials on wage-and-hour topics distributed to managers, supervisors, or employees at any of the seven at-issue properties during the preservation period must likewise be preserved.

J. Electronic Communications

VHG must preserve all emails, text messages, instant messages, chat logs, and other electronic communications of all twenty-three (23) identified custodians (see Section IV below) that relate, in whole or in part, to any of the following subjects:

• Overtime pay, overtime calculations, overtime authorization, or overtime complaints;

• Timekeeping practices, time-punch corrections, or time-rounding procedures;

• Meal breaks, rest breaks, meal-break deductions, or meal-break exceptions;

• Pre-shift or post-shift work activities, including donning and doffing, computer boot-up, shift-handover procedures, or any other activities performed before clocking in or after clocking out;

• Tips, tip pools, tip credits, or tip distribution;

• Employee classification under the FLSA, including any discussions of exempt versus non-exempt status for "lead" or "senior" positions;

• The Daniela M. Serrano demand letter or any related complaints, inquiries, or communications;

• Payroll processing, Luminos TimeTrack operations, Luminos Payroll Solutions Inc. services, or wage calculations;

• Any prior or current wage-and-hour complaints, investigations, audits, or enforcement actions involving VHG or any of the seven at-issue properties.

This preservation obligation encompasses communications on VHG's email systems (including any Ashgrove Software, Exchange, or other enterprise email platform), communications on personal devices used for business purposes by any custodian, and communications on any messaging platforms used by VHG or its employees for business purposes, including but not limited to Meridian Solutions, Northgate Data Systems, Meridian Services Inc., or similar applications.

K. Hotel Management Agreement and Palomar-Related Records

VHG must preserve the Hotel Management Agreement between VHG and Palomar Realty Partners LLC dated June 1, 2021 (Reference HMA-2021-0601-PC), relating to the Verimark Shores Clearwater property located at 455 Mandalay Avenue, Clearwater Beach, Florida 33767, as well as all amendments, addenda, side letters, exhibits, schedules, and modifications thereto.

VHG must also preserve all records relating to the employment of on-site staff at the Verimark Shores Clearwater property, including any documentation addressing joint-employer status, co-employment arrangements, or the allocation of employer responsibilities between VHG and Palomar Realty Partners LLC. The joint-employer question is likely to be a significant issue in the threatened litigation with respect to the Clearwater property, and all records bearing on this issue must be preserved.

All communications with Palomar Realty Partners LLC — including communications with its Managing Member, Ricardo E. Montalvo, at 1901 West Cypress Street, Suite 400, Tampa, Florida 33607 — relating to employment matters, staffing, payroll, HR policies, or any wage-and-hour topics must be preserved.

L. Financial and Accounting Records

VHG must preserve all payroll expense reports, labor cost analyses, and general-ledger journal entries for the seven at-issue properties during the preservation period. This includes any records relating to accruals, reserves, or contingency disclosures for wage-and-hour liabilities, whether recorded in VHG's financial statements or disclosed in the notes thereto.

VHG must also preserve all records provided to, prepared by, or received from Hargrove Kessler & Co. LLP, VHG's independent auditors (Engagement Partner: Nathaniel R. Webb, CPA), relating to labor costs, payroll liabilities, wage-and-hour contingencies, or any audit procedures performed in connection with VHG's payroll and compensation practices.

M. Insurance Records

VHG must preserve all Employment Practices Liability ("EPL") insurance policy documents, including the current policy with Pinnacle Indemnity Corp. (Policy No. PIN-EPL-2025-44781, providing $10 million per occurrence and $25 million aggregate coverage, with a $500,000 self-insured retention, for the policy period July 1, 2025 through June 30, 2026). VHG must also preserve all EPL policy documents for prior policy periods covering any portion of the preservation period (January 2021 to the present).

All claims correspondence, reservation-of-rights letters, coverage opinions, and related communications with Pinnacle Indemnity Corp. — including communications with Lydia C. Bowman, Senior Claims Examiner — must be preserved.

IV. Identified Custodians

Calderwood & Harkness has identified twenty-three (23) custodians whose documents and ESI must be preserved in connection with the threatened litigation. Each custodian must be notified of the litigation hold, must be instructed regarding their preservation obligations, and must acknowledge in writing their receipt of the litigation-hold notice. The twenty-three identified custodians are as follows:

Corporate Headquarters Custodians:

1. Devin K. Arroyo — General Counsel, VHG (Corporate Headquarters, Tampa, FL)

2. Carla S. Whitfield — Vice President, Human Resources, VHG (Corporate Headquarters, Tampa, FL)

3. Enrique J. Fuentes — Director, Payroll & Workforce Compliance, VHG (Corporate Headquarters, Tampa, FL)

4. Malik P. Jefferson — Corporate IT Administrator, VHG (Corporate Headquarters, Tampa, FL)

Property-Level HR Managers (one per at-issue property):

5. Property-Level HR Manager — Verimark Regency Tampa

6. Property-Level HR Manager — Verimark Grand Orlando

7. Property-Level HR Manager — Verimark Shores Clearwater

8. Property-Level HR Manager — Verimark Bayfront St. Petersburg

9. Property-Level HR Manager — Verimark Resort & Spa Boca Raton

10. Property-Level HR Manager — Verimark Oceanview Fort Lauderdale

11. Property-Level HR Manager — Verimark Key West Collection

Property-Level General Managers (one per at-issue property):

12. General Manager — Verimark Regency Tampa

13. General Manager — Verimark Grand Orlando

14. General Manager — Verimark Shores Clearwater

15. General Manager — Verimark Bayfront St. Petersburg

16. General Manager — Verimark Resort & Spa Boca Raton

17. General Manager — Verimark Oceanview Fort Lauderdale

18. General Manager — Verimark Key West Collection

Department Heads:

19–23. Five (5) department heads across the seven at-issue properties whose departments include hourly, non-exempt employees affected by the categories of allegations in the GLO demand letter, including but not limited to front office, housekeeping, food and beverage, and guest services departments.

Calderwood & Harkness will transmit, under separate cover, a Custodian Identification Memorandum listing each of the twenty-three custodians by full name, title, property assignment, reporting relationships, and the specific data sources and repositories under their control or in their possession. This memorandum will also identify each custodian's primary email address and any known alternative communication accounts.

As the matter progresses and Calderwood & Harkness's investigation deepens, additional custodians may be identified. VHG should promptly notify Calderwood & Harkness if the Company becomes aware of any additional individuals — whether current or former employees, contractors, or third parties — who are likely to possess documents or ESI relevant to the threatened litigation.

V. Data Systems and Repositories Subject to Preservation

In addition to preserving documents and ESI by custodian, VHG must ensure that the following data systems and repositories are subject to the litigation hold. For each system, VHG must take all steps necessary to prevent the alteration, deletion, overwriting, or destruction of data within the preservation scope.

Luminos TimeTrack — Account ID: LTT-VHG-2022-0041. All time-punch data, auto-deduction configurations (including rule AR-MEAL-030), scheduling data, time-adjustment records, and system-audit logs maintained by or through Luminos Payroll Solutions Inc. (3300 Peachtree Road NE, Suite 800, Atlanta, Georgia 30326; account contact: Shannon D. Prewitt, Senior Account Manager). Calderwood & Harkness is separately transmitting a data-preservation request letter directly to Luminos Payroll Solutions Inc. to ensure preservation of all VHG-related data in Luminos's possession, custody, or control.

VHG HRIS (Human Resource Information System) — All employee records, job classifications, compensation data, employment histories, personnel files, benefits enrollment records, and organizational charts maintained in VHG's HRIS, for all employees at the seven at-issue properties during the preservation period.

VHG Email System — All email accounts, including inboxes, sent folders, deleted items, archives, and journaled messages, for all twenty-three (23) identified custodians. VHG must immediately disable any auto-deletion policies, retention-policy purges, or mailbox-size enforcement rules that would result in the deletion of emails from custodian accounts.

VHG Document Management System — All HR policy documents, employee handbooks, internal memoranda, audit reports, compliance analyses, and other documents stored in VHG's document management system or shared network drives.

VHG Financial/ERP System — All payroll expense records, general-ledger journal entries, labor cost reports, and related accounting data maintained in VHG's enterprise resource planning (ERP) system or financial reporting platform.

Property-Level Systems — Any scheduling software, point-of-sale systems, tip-tracking applications, local databases, paper timesheets, scheduling binders, or local servers maintained at each of the seven at-issue properties that contain timekeeping, scheduling, payroll, or HR data.

Backup Tapes and Archives — All backup tapes, archived data, disaster-recovery media, and offline storage that may contain historical timekeeping, payroll, HR, or email data within the preservation period (January 2021 to present). VHG must immediately suspend any backup-tape rotation, recycling, or overwriting schedules that would result in the destruction of backup media containing data within the preservation scope.

Personal Devices — Any company-issued or personal mobile phones, tablets, or laptops used by any of the twenty-three identified custodians for business communications relating to any of the categories of documents described in Section III. Custodians should be instructed not to delete, modify, or reset any such devices without prior authorization from Calderwood & Harkness.

Pre-Luminos Timekeeping Systems — Any legacy timekeeping or payroll system used by VHG at any of the seven at-issue properties before the transition to Luminos Payroll Solutions Inc. on January 1, 2022, including any archived data, migration files, or export files from such legacy systems.

VI. Specific Preservation Instructions

The following specific instructions must be implemented immediately by all relevant VHG personnel. These instructions are mandatory, not discretionary, and apply to all twenty-three identified custodians, all seven at-issue properties, and all data systems and repositories identified in Sections III, IV, and V above.

A. Suspend Routine Document Destruction

VHG must immediately suspend all routine document-destruction policies, auto-deletion schedules, retention-policy purges, and any other systematic processes that would result in the destruction or deletion of documents or ESI within the preservation scope. This suspension applies, without limitation, to the following:

• Email auto-purge policies or mailbox retention rules that automatically delete emails after a specified period;

• Scheduled destruction of paper personnel files, payroll records, or other hard-copy documents pursuant to VHG's records-retention policy;

• Database archiving cycles, data-migration processes, or system upgrades that would overwrite, compress, or otherwise alter historical data;

• Backup-tape rotation or recycling schedules that would result in the overwriting of backup media containing data within the preservation scope;

• Any programmed deletion, purging, or data-lifecycle management process within Luminos TimeTrack, VHG's HRIS, or any other data system identified in Section V above.

B. Do Not Alter or Delete

No custodian, IT administrator, HR manager, payroll specialist, or any other VHG employee or agent should alter, delete, overwrite, modify, reformat, or otherwise destroy any potentially relevant document or ESI, whether in electronic or paper form. This prohibition extends to metadata associated with electronic files, including file-creation dates, modification dates, author information, and access history. No data should be moved from its current location or copied in a manner that would alter metadata without prior authorization from Calderwood & Harkness.

C. Collect and Segregate

Malik P. Jefferson, Corporate IT Administrator, should coordinate with property-level IT staff at each of the seven at-issue properties to identify, inventory, and segregate all backup media, archived data, and offline storage within the preservation scope. A detailed inventory of all such media should be prepared and provided to Calderwood & Harkness within ten (10) business days of this letter.

D. Paper Records

Any paper records — including paper timesheets, scheduling binders, tip-pool logs, meal-break waiver forms, employee complaint forms, and any other hard-copy documents — at the seven at-issue properties that fall within the categories described in Section III should be collected from their current locations, inventoried, and stored securely in a designated, locked storage area at each property. Paper records should not be discarded, shredded, recycled, or otherwise destroyed under any circumstances.

E. Third-Party Data

VHG must not authorize, permit, or direct Luminos Payroll Solutions Inc. to delete, overwrite, modify, or dispose of any data related to VHG's account (Account ID: LTT-VHG-2022-0041) without prior written authorization from Calderwood & Harkness. If VHG receives any communication from Luminos Payroll Solutions Inc. regarding scheduled data purges, system migrations, platform updates, or contract-term data-deletion provisions, VHG should immediately forward such communication to Calderwood & Harkness.

F. Ongoing Obligation

The litigation hold described in this letter remains in effect indefinitely and will continue until Calderwood & Harkness provides written notice that the hold may be released. The hold applies not only to documents and ESI in existence as of the date of this letter but also to all new documents and ESI created after this date that fall within the categories described in Section III. All custodians should be reminded of this ongoing obligation at regular intervals — Calderwood & Harkness recommends quarterly reminders — and should be instructed to contact VHG's General Counsel or Calderwood & Harkness if they have any questions about whether a particular document or category of information falls within the scope of the hold.

VII. Properties Covered

The preservation obligations described in this letter apply to all documents and ESI relating to the following seven at-issue properties identified in the GLO demand letter:

The total number of employees across the seven at-issue properties is approximately 2,620, of whom approximately 1,895 are hourly, non-exempt employees. The Verimark Shores Clearwater property (No. 3 above) is owned by Palomar Realty Partners LLC and managed by VHG under the Hotel Management Agreement (Reference HMA-2021-0601-PC) dated June 1, 2021, as referenced in Section III.K above.

Calderwood & Harkness reserves the right to extend the litigation hold to additional VHG-branded properties — both within and outside the State of Florida — if the scope of the threatened litigation expands beyond the seven properties identified in the GLO demand letter, or if Calderwood & Harkness's investigation reveals that potentially relevant documents or ESI exist at such additional properties.

VIII. Coordination with Calderwood & Harkness

All questions regarding the scope of the litigation hold, the identification of additional custodians, the preservation of specific categories of documents or ESI, or any other matter relating to VHG's preservation obligations in connection with the threatened litigation should be directed to the following members of the Calderwood & Harkness team:

Nadia Petrov Lead Associate Calderwood & Harkness LLP 100 Southeast Second Street, Suite 3400 Miami, Florida 33131

Ms. Petrov will serve as the primary day-to-day contact for all data collection, preservation, and ESI-related matters.

James Underwood Working Associate Calderwood & Harkness LLP 100 Southeast Second Street, Suite 3400 Miami, Florida 33131

Mr. Underwood will assist Ms. Petrov and will serve as an additional point of contact for preservation and discovery coordination.

Calderwood & Harkness recommends that VHG designate a single internal point of contact to coordinate all preservation activities across the Company. For ESI and data-systems matters, we recommend that Malik P. Jefferson, Corporate IT Administrator, serve in this capacity. For HR and personnel records, Carla S. Whitfield, Vice President of Human Resources, should serve as the coordination lead. For payroll records and timekeeping data, Enrique J. Fuentes, Director of Payroll & Workforce Compliance, should serve as the coordination lead. These three individuals should work collaboratively and maintain regular communication with Calderwood & Harkness to ensure that the preservation effort is comprehensive and consistent across all seven properties.

Calderwood & Harkness requests that VHG provide written confirmation, within five (5) business days of VHG's receipt of this letter, that:

(a) The litigation hold has been disseminated to all twenty-three (23) identified custodians, and written acknowledgments of receipt have been obtained (or are in the process of being obtained) from each custodian;

(b) All auto-deletion schedules, routine document-destruction policies, and backup-rotation schedules have been suspended for all categories of documents and ESI and all data systems identified in Sections III and V of this letter; and

(c) Luminos Payroll Solutions Inc. has been notified of VHG's obligation to preserve all data related to VHG's account (Account ID: LTT-VHG-2022-0041), or, alternatively, that VHG authorizes Calderwood & Harkness to issue the data-preservation request letter directly to Luminos Payroll Solutions Inc. on VHG's behalf.

IX. Relationship to VHG Internal Litigation-Hold Memorandum

This letter supplements the internal litigation-hold memorandum issued by VHG's General Counsel's office on January 17, 2026, one day after receipt of the GLO demand letter on January 16, 2026. Calderwood & Harkness acknowledges and commends your office's prompt action in issuing the internal hold notice. However, based on Calderwood & Harkness's review of the GLO demand letter, the scope of the threatened claims, and the breadth of VHG's data systems and operations, this letter identifies additional categories of documents, additional custodians, and additional data systems and repositories that may not have been covered by the January 17, 2026 memorandum.

To the extent that this letter identifies preservation requirements that are broader than or supplemental to the January 17, 2026 memorandum, VHG should update and reissue its internal litigation-hold notice to incorporate the expanded scope described herein. The updated notice should be distributed to all twenty-three identified custodians, and updated written acknowledgments should be obtained.

Calderwood & Harkness has prepared a draft litigation-hold notice template for distribution to the twenty-three identified custodians. This template is designed to provide custodians with clear and actionable preservation instructions while avoiding the disclosure of privileged attorney-client communications or litigation strategy. The draft template will be transmitted to your office under separate cover for your review and approval prior to distribution.

X. Privilege and Confidentiality

This letter constitutes a privileged and confidential attorney-client communication prepared by Calderwood & Harkness LLP in the course of providing legal advice to VHG in anticipation of litigation. The contents of this letter are protected by the attorney-client privilege and the work-product doctrine and should be treated as strictly confidential.

The contents of this letter should not be shared with any individual or entity outside VHG's legal department and authorized senior management without prior consultation with Calderwood & Harkness. In particular, this letter should not be forwarded to, or discussed with, opposing counsel, Luminos Payroll Solutions Inc., Palomar Realty Partners LLC, or any other third party, as such disclosure could result in a waiver of the attorney-client privilege.

The litigation-hold notice to be distributed to the twenty-three identified custodians should not disclose the substance of legal advice, litigation strategy, or case-assessment analyses provided by Calderwood & Harkness. The draft litigation-hold notice template prepared by Calderwood & Harkness has been carefully designed to provide appropriate and necessary preservation instructions to custodians without disclosing privileged information or waiving any applicable privilege.

XI. Consequences of Non-Compliance

Calderwood & Harkness wishes to emphasize, in the strongest possible terms, the serious consequences that can result from a failure to preserve relevant documents and ESI. Courts have consistently held that a party's failure to take reasonable steps to preserve evidence in anticipation of litigation may result in any or all of the following:

• Spoliation sanctions under Federal Rule of Civil Procedure 37(e), including curative measures, preclusion of evidence, and — where a court finds that the party acted with intent to deprive the opposing party of the information — an adverse-inference instruction, dismissal of claims or defenses, or entry of default judgment;

• Adverse-inference jury instructions directing the jury that it may, or must, presume that the lost or destroyed information was unfavorable to VHG;

• Monetary sanctions and awards of attorneys' fees and costs incurred by the opposing party as a result of the spoliation;

• Potential personal liability for individuals within the organization who intentionally destroy, conceal, or alter evidence, including potential contempt of court sanctions and, in extreme cases, criminal penalties.

All custodians must treat the litigation hold as mandatory, non-discretionary, and ongoing. Compliance with the litigation hold is not optional and is not subject to business-convenience exceptions. Any custodian who has questions about whether a particular document or category of information falls within the scope of the hold should err on the side of preservation and contact VHG's General Counsel or Calderwood & Harkness for guidance.

XII. Closing

We request that VHG provide written confirmation of its compliance with the instructions set forth in this letter within five (5) business days of receipt. Calderwood & Harkness stands ready to schedule a conference call or in-person meeting with VHG's legal, human resources, information technology, and payroll teams at the earliest practicable date to discuss the implementation of the litigation hold, the coordination of data collection and preservation activities, and any questions or concerns that may arise.

Calderwood & Harkness will continue to advise VHG on its preservation obligations as this matter develops, and will supplement the instructions in this letter as necessary in light of new information, changes in the scope of the threatened litigation, or the commencement of formal proceedings.

We appreciate VHG's commitment to fulfilling its preservation obligations and look forward to working closely with you and your team on this matter.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Bernard Crawford Responsible Partner, Labor & Employment Calderwood & Harkness LLP 100 Southeast Second Street, Suite 3400 Miami, Florida 33131 Telephone: (305) 884-7200

Email: bcrawford@calderwoodharkness.com

cc: (via email)

Theodore R. Langford, Chief Executive Officer, Verimark Hospitality Group Inc.

Marguerite A. Dunning, Chief Financial Officer, 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.

Renata Vasquez, Billing Partner, Calderwood & Harkness LLP

CALDERWOOD & HARKNESS LLP Attorneys at Law
100 Southeast Second Street, Suite 3400 Miami, Florida 33131
Telephone: (305) 884-7200 Facsimile: (305) 884-7201 www.calderwoodharkness.com
February 3, 2026
VIA EMAIL AND CERTIFIED MAIL RETURN RECEIPT REQUESTED
Devin K. Arroyo, Esq. General Counsel Verimark Hospitality Group Inc. 2400 Bayshore Boulevard, Suite 1100 Tampa, Florida 33629
Re: Litigation Hold Advisory — Preservation of Documents and Electronically Stored Information
Demand of Daniela M. Serrano; Garza, Linden & Okafor LLP Demand Letter dated January 14, 2026
Threatened FLSA Collective / Class Action — Wage-and-Hour Claims
Calderwood & Harkness Matter No. 1021-00005
Dear Mr. Arroyo:
I. Purpose and Background
I write in my capacity as Responsible Partner, Labor & Employment, at Calderwood & Harkness LLP, to provide Verimark Hospitality Group Inc. ("VHG" or "the Company") with formal outside counsel guidance regarding VHG's document- and data-preservation obligations arising from the threatened wage-and-hour litigation described herein. This letter is addressed to you in your capacity as General Counsel of VHG and is intended to be shared, as appropriate and in accordance with the privilege guidance set forth in Section X below, with the individuals and departments responsible for implementing and overseeing VHG's preservation efforts.
As you are aware, on or about January 14, 2026, Marco A. Garza of Garza, Linden & Okafor LLP ("GLO"), 600 Brickell Avenue, Suite 2200, Miami, Florida 33131, transmitted a demand letter on behalf of his client, Daniela M. Serrano (Employee ID VHG-EMP-20220314-5587), a former front-desk associate at the Verimark Regency Tampa property. Ms. Serrano was employed by VHG from March 14, 2022 through August 22, 2025. Your office received the GLO demand letter on January 16, 2026.
The GLO demand letter threatens to initiate a collective action under Section 16(b) of the Fair Labor Standards Act, 29 U.S.C. § 216(b), as well as a class action under the Florida Constitution, Article X, Section 24, alleging systemic wage-and-hour violations across seven Verimark-branded hotel and resort properties in the State of Florida. The demand letter identifies a putative collective and class consisting of all current and former hourly, non-exempt employees at the seven Verimark-branded properties in Florida from January 2023 to the present — a group estimated by GLO to encompass approximately 4,100 to 5,900 individuals. The demand letter claims damages of approximately $18.5 million, inclusive of back pay, liquidated damages, and attorneys' fees, and imposes a response deadline of February 28, 2026.
Calderwood & Harkness was engaged by VHG on January 30, 2026, following authorization by the VHG Audit Committee on January 29, 2026, to represent the Company in connection with the threatened litigation and to provide comprehensive legal counsel on all related matters, including preservation, pre-litigation strategy, and defense.
This letter supplements and is intended to formalize and strengthen VHG's internal litigation-hold memorandum issued by your office on January 17, 2026 — one day after receipt of the GLO demand letter. Your prompt action in issuing the internal hold was both appropriate and commendable. Nevertheless, based on our review of the scope of the threatened claims, the breadth of the putative collective and class, and the data systems and records implicated, Calderwood & Harkness has determined that additional specificity and formalization of VHG's preservation obligations is warranted. This letter provides that additional guidance.
The Company's obligation to preserve all relevant documents and electronically stored information ("ESI") arose no later than January 16, 2026, when your office received the GLO demand letter, thereby triggering a duty to preserve under both federal and Florida law. As detailed below, the scope of that obligation is broad and extends across multiple categories of documents, data systems, and custodians.
II. Legal Obligation to Preserve
The duty to preserve relevant evidence arises when a party knows or reasonably should know that litigation is likely. Here, VHG's duty to preserve was triggered no later than January 16, 2026, upon receipt of the GLO demand letter, which unambiguously threatened the commencement of a collective and class action in federal court. The receipt of that demand letter placed VHG on clear notice that litigation was reasonably anticipated, and preservation obligations attached at that time.
The legal consequences of failing to meet this obligation are significant. Under Federal Rule of Civil Procedure 37(e), if ESI that should have been preserved in the anticipation or conduct of litigation is lost because a party failed to take reasonable steps to preserve it, and the information cannot be restored or replaced through additional discovery, the court may order measures no greater than necessary to cure the prejudice — or, upon a finding of intent to deprive another party of the information's use, may presume the lost information was unfavorable to the party that failed to preserve it, instruct the jury that it may or must presume the information was unfavorable, or dismiss the action or enter a default judgment. Additionally, Federal Rule of Civil Procedure 26(g) imposes an affirmative obligation on parties and their counsel to certify that discovery responses are complete and accurate, which presupposes adequate preservation. Florida courts likewise recognize spoliation as a basis for adverse-inference instructions, sanctions, and, in egregious cases, independent tort liability.
The scope of VHG's preservation obligation extends to all documents and ESI that are relevant to, or reasonably likely to be relevant to, the claims and defenses in the anticipated litigation, including documents that may be relevant to damages calculations, class and collective certification, and affirmative defenses.
Given the nature and breadth of the allegations raised in the GLO demand letter, the preservation obligation is necessarily broad. The demand letter identifies five categories of substantive allegations:
1. Overtime violations under 29 U.S.C. § 207(a), including allegations that VHG failed to compensate hourly, non-exempt employees for all hours worked in excess of forty (40) hours in a workweek at a rate of not less than one and one-half times the employee's regular rate of pay;
2. Illegal automatic meal-break deductions, including allegations that VHG's timekeeping system automatically deducted thirty (30) minutes from employee time records for each shift of six (6) or more hours, regardless of whether the employee was actually relieved of all duties during the meal break;
3. Failure to compensate pre-shift and post-shift work, including allegations that VHG required hourly employees to perform compensable work activities — such as computer boot-up, system logins, shift-handover briefings, and uniform donning and doffing — before clocking in and after clocking out;
4. Florida tipped-employee minimum wage violations, including allegations that VHG failed to pay certain tipped employees the applicable Florida minimum wage, taking into account the tip credit claimed by VHG, and failed to provide adequate notice of the tip credit to affected employees as required under the FLSA and Florida law; and
5. Misclassification of "lead" and "senior" hourly roles under the FLSA administrative exemption, including allegations that VHG improperly classified certain positions designated as "lead" or "senior" as exempt from the FLSA's overtime requirements when such positions did not satisfy the duties test for the administrative exemption under 29 C.F.R. § 541.200.
The applicable statutes of limitations determine the temporal scope of VHG's preservation obligation. The relevant limitations periods are as follows:
• FLSA willful violations: Three-year lookback from the date of the demand letter, reaching back to January 14, 2023 (29 U.S.C. § 255(a));
• FLSA non-willful violations: Two-year lookback from the date of the demand letter, reaching back to January 14, 2024 (29 U.S.C. § 255(a)); and
• Florida constitutional minimum-wage claims: Five-year statute of limitations under Florida Statutes § 95.11(2)(b), reaching back to January 14, 2021.
In light of the foregoing, and to ensure that VHG's preservation efforts cover the longest applicable limitations period with a reasonable cushion, Calderwood & Harkness recommends that VHG preserve all relevant documents and ESI from January 1, 2021 to the present. This recommended preservation window encompasses the full five-year lookback for the Florida constitutional claims, with a two-week buffer to account for any potential disputes regarding the accrual date, as well as the shorter FLSA limitations periods.
III. Categories of Documents and ESI to Be Preserved
The following is a comprehensive, though not necessarily exhaustive, list of the categories of documents and ESI that must be preserved. VHG should preserve all documents and ESI falling within the categories described below for all seven at-issue properties (identified in Section VII) and for the preservation period of January 1, 2021 to the present, unless a different scope is specified below. If any VHG employee, manager, or officer becomes aware of additional categories of potentially relevant documents or data not identified below, that information should be brought to the attention of Calderwood & Harkness immediately.
A. Timekeeping and Punch Data
VHG must preserve all time-punch records, clock-in/clock-out data, and time entries from the Luminos TimeTrack platform (Account ID: LTT-VHG-2022-0041) for all hourly, non-exempt employees at each of the seven at-issue properties from January 2021 to the present. This encompasses the full universe of electronic timekeeping data maintained by VHG through Luminos Payroll Solutions Inc.
Additionally, VHG must preserve all timekeeping data from any prior timekeeping system used by VHG before the Company's transition to Luminos Payroll Solutions Inc. on January 1, 2022. To the extent that historical timekeeping data from such legacy systems has been migrated to Luminos TimeTrack or retained in a separate archive or database, all such data must be preserved intact.
VHG must also preserve all records of manual time adjustments, edits, overrides, or corrections made to time-punch records at any time during the preservation period, whether such adjustments were initiated by employees, supervisors, property-level HR managers, or payroll personnel. This includes records of the identity of the individual who made the adjustment, the date and time of the adjustment, the original and modified values, and any reason codes or notations associated with the adjustment.
All system-audit logs and change-history logs generated by Luminos TimeTrack, including logs that record user access, data modifications, configuration changes, and error events, must be preserved in their native format.
B. Payroll Records
VHG must preserve all payroll registers, pay stubs, wage statements, and earnings records for all non-exempt, hourly employees at the seven at-issue properties for the preservation period. This includes both electronic payroll records maintained by VHG and any records maintained by Luminos Payroll Solutions Inc. on VHG's behalf.
VHG must also preserve all records relating to overtime calculations, including the algorithms, formulas, and configuration settings used by Luminos Payroll Solutions Inc. to calculate overtime pay for VHG employees. This includes documentation of the regular rate of pay calculation methodology, including any adjustments made for tips, non-discretionary bonuses, shift differentials, or other forms of remuneration that are required to be included in the regular rate under the FLSA.
All records relating to Luminos Payroll Solutions Inc.'s processing of VHG's payroll must be preserved, including the master service agreement between VHG and Luminos Payroll Solutions Inc., all statements of work, configuration documentation, implementation records, change orders, and any correspondence regarding payroll processing errors, discrepancies, or compliance concerns.
C. Automatic Meal-Break Deduction Records
Given the centrality of the automatic meal-break deduction allegations to the threatened litigation, VHG must preserve with particular care all records relating to the automatic meal-break deduction configuration within Luminos TimeTrack — specifically, the auto-deduction rule designated as AR-MEAL-030, which is configured to automatically deduct thirty (30) minutes from an employee's recorded work time for each shift of six (6) or more hours.
VHG must preserve the complete configuration history for rule AR-MEAL-030, including the date the rule was initially implemented, any subsequent modifications, overrides, exceptions, or temporary suspensions of the rule, and the identity of any VHG or Luminos personnel who authorized or implemented such changes.
VHG must also preserve all records relating to any meal-break exception or correction process — that is, any procedure by which employees could report that they were not fully relieved of duties during an automatically deducted meal break and request a correction to their time records. This includes any forms, electronic submissions, supervisor approvals, or payroll adjustments associated with such corrections.
Additionally, all meal-break waivers, acknowledgment forms, sign-off sheets, or other documentation by which employees purportedly agreed to the automatic deduction or waived their right to a meal break must be preserved.
D. Scheduling Records
VHG must preserve all employee work schedules, shift assignments, and scheduling templates for each of the seven at-issue properties during the preservation period. This includes both electronic scheduling records and any paper-based scheduling documents, such as scheduling binders or posted schedules.
Records of schedule changes, shift swaps, on-call designations, and any other modifications to posted or electronic schedules must also be preserved. VHG should further preserve any records showing the comparison between scheduled shift start and end times and actual clock-in and clock-out times, as such records may be relevant to the pre-shift and post-shift work allegations.
E. Employee Handbooks, Policies, and Procedures
VHG must preserve all versions of the VHG employee handbook in effect at any time during the preservation period. This includes the current version (v.7.2, effective January 1, 2025) and all prior versions, drafts, and redlined revisions. To the extent that different versions of the handbook were in effect at different properties or at different times, all such versions must be preserved.
In addition to the employee handbook, VHG must preserve all standalone policies, procedures, standard operating procedures, training materials, and management directives relating to the following subjects:
• Meal-break and rest-break policies, including any policies governing the circumstances under which an employee may be required to remain on duty or on premises during a meal break;
• Overtime authorization and approval policies, including any policies requiring advance authorization for overtime work and any policies regarding the consequences of unauthorized overtime;
• Uniform and dress-code policies, including any donning and doffing requirements, grooming standards, or procedures requiring employees to change into or out of uniforms, safety equipment, or other attire on the employer's premises;
• Pre-shift and post-shift duty requirements, including any policies or practices relating to computer boot-up procedures, system logins, register preparation, shift-handover briefings, security checks, or other activities performed before or after an employee's scheduled shift;
• Tip-pool policies, tip-credit notices, and tip distribution records, including any written notices provided to tipped employees regarding the employer's use of a tip credit;
• Timekeeping policies, including policies governing clock-in and clock-out procedures, time-rounding rules, and the process for correcting timekeeping errors.
F. Job Descriptions and Classification Records
VHG must preserve all job descriptions for hourly, non-exempt positions at each of the seven at-issue properties, including any revisions to such job descriptions during the preservation period. This encompasses job descriptions for front-desk associates, concierge staff, housekeeping personnel, food and beverage workers, maintenance technicians, and all other hourly positions.
Of particular importance to the misclassification allegations, VHG must preserve all job descriptions and classification analyses for positions designated as "lead" or "senior" that are alleged to have been improperly classified as exempt under the FLSA administrative exemption. This includes any FLSA exemption classification worksheets, analyses, memoranda, or opinions prepared by VHG's in-house legal department, HR department, or any outside consultants or law firms. Any records of reclassification actions — that is, instances in which VHG changed the classification of a position from exempt to non-exempt or vice versa — must also be preserved, along with the reasons for such reclassification.
G. Tip-Pool and Tip-Credit Records
VHG must preserve all tip-pool distribution records for front-desk, concierge, valet, bellhop, and any other positions participating in tip pools at the seven at-issue properties during the preservation period. This includes records showing the total tips received, the methodology for distributing tips among participants, the amounts distributed to each participant, and any management involvement in the tip-pool process.
VHG must further preserve all tip-credit notices provided to tipped employees, whether in writing or electronically, including any acknowledgment forms signed by employees. Records showing the hourly cash wage paid to tipped employees — currently $10.98 per hour, based on the Florida tipped minimum wage of $14.00 per hour minus the $3.02 tip credit — must be preserved, along with any records showing historical changes to these rates during the preservation period. All records of total tips received and distributed to individual employees, including any records maintained by employees or supervisors, must be preserved.
H. Employment Records
VHG must preserve the complete personnel file for Daniela M. Serrano (Employee ID VHG-EMP-20220314-5587), including but not limited to her application, offer letter, employment agreement, performance evaluations, disciplinary records, compensation history, benefits enrollment, and separation documentation.
More broadly, VHG must preserve offer letters, employment agreements, and separation documents — including resignation letters, termination notices, and separation agreements — for all current and former hourly employees at the seven at-issue properties during the preservation period. Employment eligibility records, including I-9 forms, should be preserved to the extent they are relevant to establishing employment dates and eligibility.
VHG must also preserve all records of employee complaints, grievances, or inquiries relating to pay, overtime, meal breaks, timekeeping, tip distribution, or any other wage-and-hour topic, whether submitted formally through a grievance procedure, informally through conversations with supervisors or HR, or through any anonymous reporting mechanism.
I. Internal Audit and Compliance Records
VHG must preserve all internal audit reports, compliance reviews, risk assessments, and related work papers that address or relate to wage-and-hour compliance, payroll accuracy, timekeeping practices, or FLSA compliance at any of the seven at-issue properties during the preservation period. This includes reports prepared by or at the direction of the Director of Payroll & Workforce Compliance, Enrique J. Fuentes, as well as reports prepared by or at the direction of the Vice President of Human Resources, Carla S. Whitfield.
Any reports, memoranda, analyses, or presentations prepared by Mr. Fuentes, Ms. Whitfield, or their respective staffs regarding wage-and-hour issues, including gap analyses, remediation plans, or compliance roadmaps, must be preserved.
VHG must also preserve any correspondence with Luminos Payroll Solutions Inc. — including correspondence with Shannon D. Prewitt, Senior Account Manager — regarding payroll processing errors, configuration issues, system malfunctions, data discrepancies, or compliance concerns. This includes email correspondence, meeting notes, trouble tickets, and service-level reports.
All compliance training materials on wage-and-hour topics distributed to managers, supervisors, or employees at any of the seven at-issue properties during the preservation period must likewise be preserved.
J. Electronic Communications
VHG must preserve all emails, text messages, instant messages, chat logs, and other electronic communications of all twenty-three (23) identified custodians (see Section IV below) that relate, in whole or in part, to any of the following subjects:
• Overtime pay, overtime calculations, overtime authorization, or overtime complaints;
• Timekeeping practices, time-punch corrections, or time-rounding procedures;
• Meal breaks, rest breaks, meal-break deductions, or meal-break exceptions;
• Pre-shift or post-shift work activities, including donning and doffing, computer boot-up, shift-handover procedures, or any other activities performed before clocking in or after clocking out;
• Tips, tip pools, tip credits, or tip distribution;
• Employee classification under the FLSA, including any discussions of exempt versus non-exempt status for "lead" or "senior" positions;
• The Daniela M. Serrano demand letter or any related complaints, inquiries, or communications;
• Payroll processing, Luminos TimeTrack operations, Luminos Payroll Solutions Inc. services, or wage calculations;
• Any prior or current wage-and-hour complaints, investigations, audits, or enforcement actions involving VHG or any of the seven at-issue properties.
This preservation obligation encompasses communications on VHG's email systems (including any Ashgrove Software, Exchange, or other enterprise email platform), communications on personal devices used for business purposes by any custodian, and communications on any messaging platforms used by VHG or its employees for business purposes, including but not limited to Meridian Solutions, Northgate Data Systems, Meridian Services Inc., or similar applications.
K. Hotel Management Agreement and Palomar-Related Records
VHG must preserve the Hotel Management Agreement between VHG and Palomar Realty Partners LLC dated June 1, 2021 (Reference HMA-2021-0601-PC), relating to the Verimark Shores Clearwater property located at 455 Mandalay Avenue, Clearwater Beach, Florida 33767, as well as all amendments, addenda, side letters, exhibits, schedules, and modifications thereto.
VHG must also preserve all records relating to the employment of on-site staff at the Verimark Shores Clearwater property, including any documentation addressing joint-employer status, co-employment arrangements, or the allocation of employer responsibilities between VHG and Palomar Realty Partners LLC. The joint-employer question is likely to be a significant issue in the threatened litigation with respect to the Clearwater property, and all records bearing on this issue must be preserved.
All communications with Palomar Realty Partners LLC — including communications with its Managing Member, Ricardo E. Montalvo, at 1901 West Cypress Street, Suite 400, Tampa, Florida 33607 — relating to employment matters, staffing, payroll, HR policies, or any wage-and-hour topics must be preserved.
L. Financial and Accounting Records
VHG must preserve all payroll expense reports, labor cost analyses, and general-ledger journal entries for the seven at-issue properties during the preservation period. This includes any records relating to accruals, reserves, or contingency disclosures for wage-and-hour liabilities, whether recorded in VHG's financial statements or disclosed in the notes thereto.
VHG must also preserve all records provided to, prepared by, or received from Hargrove Kessler & Co. LLP, VHG's independent auditors (Engagement Partner: Nathaniel R. Webb, CPA), relating to labor costs, payroll liabilities, wage-and-hour contingencies, or any audit procedures performed in connection with VHG's payroll and compensation practices.
M. Insurance Records
VHG must preserve all Employment Practices Liability ("EPL") insurance policy documents, including the current policy with Pinnacle Indemnity Corp. (Policy No. PIN-EPL-2025-44781, providing $10 million per occurrence and $25 million aggregate coverage, with a $500,000 self-insured retention, for the policy period July 1, 2025 through June 30, 2026). VHG must also preserve all EPL policy documents for prior policy periods covering any portion of the preservation period (January 2021 to the present).
All claims correspondence, reservation-of-rights letters, coverage opinions, and related communications with Pinnacle Indemnity Corp. — including communications with Lydia C. Bowman, Senior Claims Examiner — must be preserved.
IV. Identified Custodians
Calderwood & Harkness has identified twenty-three (23) custodians whose documents and ESI must be preserved in connection with the threatened litigation. Each custodian must be notified of the litigation hold, must be instructed regarding their preservation obligations, and must acknowledge in writing their receipt of the litigation-hold notice. The twenty-three identified custodians are as follows:
Corporate Headquarters Custodians:
1. Devin K. Arroyo — General Counsel, VHG (Corporate Headquarters, Tampa, FL)
2. Carla S. Whitfield — Vice President, Human Resources, VHG (Corporate Headquarters, Tampa, FL)
3. Enrique J. Fuentes — Director, Payroll & Workforce Compliance, VHG (Corporate Headquarters, Tampa, FL)
4. Malik P. Jefferson — Corporate IT Administrator, VHG (Corporate Headquarters, Tampa, FL)
Property-Level HR Managers (one per at-issue property):
5. Property-Level HR Manager — Verimark Regency Tampa
6. Property-Level HR Manager — Verimark Grand Orlando
7. Property-Level HR Manager — Verimark Shores Clearwater
8. Property-Level HR Manager — Verimark Bayfront St. Petersburg
9. Property-Level HR Manager — Verimark Resort & Spa Boca Raton
10. Property-Level HR Manager — Verimark Oceanview Fort Lauderdale
11. Property-Level HR Manager — Verimark Key West Collection
Property-Level General Managers (one per at-issue property):
12. General Manager — Verimark Regency Tampa
13. General Manager — Verimark Grand Orlando
14. General Manager — Verimark Shores Clearwater
15. General Manager — Verimark Bayfront St. Petersburg
16. General Manager — Verimark Resort & Spa Boca Raton
17. General Manager — Verimark Oceanview Fort Lauderdale
18. General Manager — Verimark Key West Collection
Department Heads:
19–23. Five (5) department heads across the seven at-issue properties whose departments include hourly, non-exempt employees affected by the categories of allegations in the GLO demand letter, including but not limited to front office, housekeeping, food and beverage, and guest services departments.
Calderwood & Harkness will transmit, under separate cover, a Custodian Identification Memorandum listing each of the twenty-three custodians by full name, title, property assignment, reporting relationships, and the specific data sources and repositories under their control or in their possession. This memorandum will also identify each custodian's primary email address and any known alternative communication accounts.
As the matter progresses and Calderwood & Harkness's investigation deepens, additional custodians may be identified. VHG should promptly notify Calderwood & Harkness if the Company becomes aware of any additional individuals — whether current or former employees, contractors, or third parties — who are likely to possess documents or ESI relevant to the threatened litigation.
V. Data Systems and Repositories Subject to Preservation
In addition to preserving documents and ESI by custodian, VHG must ensure that the following data systems and repositories are subject to the litigation hold. For each system, VHG must take all steps necessary to prevent the alteration, deletion, overwriting, or destruction of data within the preservation scope.
Luminos TimeTrack — Account ID: LTT-VHG-2022-0041. All time-punch data, auto-deduction configurations (including rule AR-MEAL-030), scheduling data, time-adjustment records, and system-audit logs maintained by or through Luminos Payroll Solutions Inc. (3300 Peachtree Road NE, Suite 800, Atlanta, Georgia 30326; account contact: Shannon D. Prewitt, Senior Account Manager). Calderwood & Harkness is separately transmitting a data-preservation request letter directly to Luminos Payroll Solutions Inc. to ensure preservation of all VHG-related data in Luminos's possession, custody, or control.
VHG HRIS (Human Resource Information System) — All employee records, job classifications, compensation data, employment histories, personnel files, benefits enrollment records, and organizational charts maintained in VHG's HRIS, for all employees at the seven at-issue properties during the preservation period.
VHG Email System — All email accounts, including inboxes, sent folders, deleted items, archives, and journaled messages, for all twenty-three (23) identified custodians. VHG must immediately disable any auto-deletion policies, retention-policy purges, or mailbox-size enforcement rules that would result in the deletion of emails from custodian accounts.
VHG Document Management System — All HR policy documents, employee handbooks, internal memoranda, audit reports, compliance analyses, and other documents stored in VHG's document management system or shared network drives.
VHG Financial/ERP System — All payroll expense records, general-ledger journal entries, labor cost reports, and related accounting data maintained in VHG's enterprise resource planning (ERP) system or financial reporting platform.
Property-Level Systems — Any scheduling software, point-of-sale systems, tip-tracking applications, local databases, paper timesheets, scheduling binders, or local servers maintained at each of the seven at-issue properties that contain timekeeping, scheduling, payroll, or HR data.
Backup Tapes and Archives — All backup tapes, archived data, disaster-recovery media, and offline storage that may contain historical timekeeping, payroll, HR, or email data within the preservation period (January 2021 to present). VHG must immediately suspend any backup-tape rotation, recycling, or overwriting schedules that would result in the destruction of backup media containing data within the preservation scope.
Personal Devices — Any company-issued or personal mobile phones, tablets, or laptops used by any of the twenty-three identified custodians for business communications relating to any of the categories of documents described in Section III. Custodians should be instructed not to delete, modify, or reset any such devices without prior authorization from Calderwood & Harkness.
Pre-Luminos Timekeeping Systems — Any legacy timekeeping or payroll system used by VHG at any of the seven at-issue properties before the transition to Luminos Payroll Solutions Inc. on January 1, 2022, including any archived data, migration files, or export files from such legacy systems.
VI. Specific Preservation Instructions
The following specific instructions must be implemented immediately by all relevant VHG personnel. These instructions are mandatory, not discretionary, and apply to all twenty-three identified custodians, all seven at-issue properties, and all data systems and repositories identified in Sections III, IV, and V above.
A. Suspend Routine Document Destruction
VHG must immediately suspend all routine document-destruction policies, auto-deletion schedules, retention-policy purges, and any other systematic processes that would result in the destruction or deletion of documents or ESI within the preservation scope. This suspension applies, without limitation, to the following:
• Email auto-purge policies or mailbox retention rules that automatically delete emails after a specified period;
• Scheduled destruction of paper personnel files, payroll records, or other hard-copy documents pursuant to VHG's records-retention policy;
• Database archiving cycles, data-migration processes, or system upgrades that would overwrite, compress, or otherwise alter historical data;
• Backup-tape rotation or recycling schedules that would result in the overwriting of backup media containing data within the preservation scope;
• Any programmed deletion, purging, or data-lifecycle management process within Luminos TimeTrack, VHG's HRIS, or any other data system identified in Section V above.
B. Do Not Alter or Delete
No custodian, IT administrator, HR manager, payroll specialist, or any other VHG employee or agent should alter, delete, overwrite, modify, reformat, or otherwise destroy any potentially relevant document or ESI, whether in electronic or paper form. This prohibition extends to metadata associated with electronic files, including file-creation dates, modification dates, author information, and access history. No data should be moved from its current location or copied in a manner that would alter metadata without prior authorization from Calderwood & Harkness.
C. Collect and Segregate
Malik P. Jefferson, Corporate IT Administrator, should coordinate with property-level IT staff at each of the seven at-issue properties to identify, inventory, and segregate all backup media, archived data, and offline storage within the preservation scope. A detailed inventory of all such media should be prepared and provided to Calderwood & Harkness within ten (10) business days of this letter.
D. Paper Records
Any paper records — including paper timesheets, scheduling binders, tip-pool logs, meal-break waiver forms, employee complaint forms, and any other hard-copy documents — at the seven at-issue properties that fall within the categories described in Section III should be collected from their current locations, inventoried, and stored securely in a designated, locked storage area at each property. Paper records should not be discarded, shredded, recycled, or otherwise destroyed under any circumstances.
E. Third-Party Data
VHG must not authorize, permit, or direct Luminos Payroll Solutions Inc. to delete, overwrite, modify, or dispose of any data related to VHG's account (Account ID: LTT-VHG-2022-0041) without prior written authorization from Calderwood & Harkness. If VHG receives any communication from Luminos Payroll Solutions Inc. regarding scheduled data purges, system migrations, platform updates, or contract-term data-deletion provisions, VHG should immediately forward such communication to Calderwood & Harkness.
F. Ongoing Obligation
The litigation hold described in this letter remains in effect indefinitely and will continue until Calderwood & Harkness provides written notice that the hold may be released. The hold applies not only to documents and ESI in existence as of the date of this letter but also to all new documents and ESI created after this date that fall within the categories described in Section III. All custodians should be reminded of this ongoing obligation at regular intervals — Calderwood & Harkness recommends quarterly reminders — and should be instructed to contact VHG's General Counsel or Calderwood & Harkness if they have any questions about whether a particular document or category of information falls within the scope of the hold.
VII. Properties Covered
The preservation obligations described in this letter apply to all documents and ESI relating to the following seven at-issue properties identified in the GLO demand letter:
The total number of employees across the seven at-issue properties is approximately 2,620, of whom approximately 1,895 are hourly, non-exempt employees. The Verimark Shores Clearwater property (No. 3 above) is owned by Palomar Realty Partners LLC and managed by VHG under the Hotel Management Agreement (Reference HMA-2021-0601-PC) dated June 1, 2021, as referenced in Section III.K above.
Calderwood & Harkness reserves the right to extend the litigation hold to additional VHG-branded properties — both within and outside the State of Florida — if the scope of the threatened litigation expands beyond the seven properties identified in the GLO demand letter, or if Calderwood & Harkness's investigation reveals that potentially relevant documents or ESI exist at such additional properties.
VIII. Coordination with Calderwood & Harkness
All questions regarding the scope of the litigation hold, the identification of additional custodians, the preservation of specific categories of documents or ESI, or any other matter relating to VHG's preservation obligations in connection with the threatened litigation should be directed to the following members of the Calderwood & Harkness team:
Nadia Petrov Lead Associate Calderwood & Harkness LLP 100 Southeast Second Street, Suite 3400 Miami, Florida 33131
Ms. Petrov will serve as the primary day-to-day contact for all data collection, preservation, and ESI-related matters.
James Underwood Working Associate Calderwood & Harkness LLP 100 Southeast Second Street, Suite 3400 Miami, Florida 33131
Mr. Underwood will assist Ms. Petrov and will serve as an additional point of contact for preservation and discovery coordination.
Calderwood & Harkness recommends that VHG designate a single internal point of contact to coordinate all preservation activities across the Company. For ESI and data-systems matters, we recommend that Malik P. Jefferson, Corporate IT Administrator, serve in this capacity. For HR and personnel records, Carla S. Whitfield, Vice President of Human Resources, should serve as the coordination lead. For payroll records and timekeeping data, Enrique J. Fuentes, Director of Payroll & Workforce Compliance, should serve as the coordination lead. These three individuals should work collaboratively and maintain regular communication with Calderwood & Harkness to ensure that the preservation effort is comprehensive and consistent across all seven properties.
Calderwood & Harkness requests that VHG provide written confirmation, within five (5) business days of VHG's receipt of this letter, that:
(a) The litigation hold has been disseminated to all twenty-three (23) identified custodians, and written acknowledgments of receipt have been obtained (or are in the process of being obtained) from each custodian;
(b) All auto-deletion schedules, routine document-destruction policies, and backup-rotation schedules have been suspended for all categories of documents and ESI and all data systems identified in Sections III and V of this letter; and
(c) Luminos Payroll Solutions Inc. has been notified of VHG's obligation to preserve all data related to VHG's account (Account ID: LTT-VHG-2022-0041), or, alternatively, that VHG authorizes Calderwood & Harkness to issue the data-preservation request letter directly to Luminos Payroll Solutions Inc. on VHG's behalf.
IX. Relationship to VHG Internal Litigation-Hold Memorandum
This letter supplements the internal litigation-hold memorandum issued by VHG's General Counsel's office on January 17, 2026, one day after receipt of the GLO demand letter on January 16, 2026. Calderwood & Harkness acknowledges and commends your office's prompt action in issuing the internal hold notice. However, based on Calderwood & Harkness's review of the GLO demand letter, the scope of the threatened claims, and the breadth of VHG's data systems and operations, this letter identifies additional categories of documents, additional custodians, and additional data systems and repositories that may not have been covered by the January 17, 2026 memorandum.
To the extent that this letter identifies preservation requirements that are broader than or supplemental to the January 17, 2026 memorandum, VHG should update and reissue its internal litigation-hold notice to incorporate the expanded scope described herein. The updated notice should be distributed to all twenty-three identified custodians, and updated written acknowledgments should be obtained.
Calderwood & Harkness has prepared a draft litigation-hold notice template for distribution to the twenty-three identified custodians. This template is designed to provide custodians with clear and actionable preservation instructions while avoiding the disclosure of privileged attorney-client communications or litigation strategy. The draft template will be transmitted to your office under separate cover for your review and approval prior to distribution.
X. Privilege and Confidentiality
This letter constitutes a privileged and confidential attorney-client communication prepared by Calderwood & Harkness LLP in the course of providing legal advice to VHG in anticipation of litigation. The contents of this letter are protected by the attorney-client privilege and the work-product doctrine and should be treated as strictly confidential.
The contents of this letter should not be shared with any individual or entity outside VHG's legal department and authorized senior management without prior consultation with Calderwood & Harkness. In particular, this letter should not be forwarded to, or discussed with, opposing counsel, Luminos Payroll Solutions Inc., Palomar Realty Partners LLC, or any other third party, as such disclosure could result in a waiver of the attorney-client privilege.
The litigation-hold notice to be distributed to the twenty-three identified custodians should not disclose the substance of legal advice, litigation strategy, or case-assessment analyses provided by Calderwood & Harkness. The draft litigation-hold notice template prepared by Calderwood & Harkness has been carefully designed to provide appropriate and necessary preservation instructions to custodians without disclosing privileged information or waiving any applicable privilege.
XI. Consequences of Non-Compliance
Calderwood & Harkness wishes to emphasize, in the strongest possible terms, the serious consequences that can result from a failure to preserve relevant documents and ESI. Courts have consistently held that a party's failure to take reasonable steps to preserve evidence in anticipation of litigation may result in any or all of the following:
• Spoliation sanctions under Federal Rule of Civil Procedure 37(e), including curative measures, preclusion of evidence, and — where a court finds that the party acted with intent to deprive the opposing party of the information — an adverse-inference instruction, dismissal of claims or defenses, or entry of default judgment;
• Adverse-inference jury instructions directing the jury that it may, or must, presume that the lost or destroyed information was unfavorable to VHG;
• Monetary sanctions and awards of attorneys' fees and costs incurred by the opposing party as a result of the spoliation;
• Potential personal liability for individuals within the organization who intentionally destroy, conceal, or alter evidence, including potential contempt of court sanctions and, in extreme cases, criminal penalties.
All custodians must treat the litigation hold as mandatory, non-discretionary, and ongoing. Compliance with the litigation hold is not optional and is not subject to business-convenience exceptions. Any custodian who has questions about whether a particular document or category of information falls within the scope of the hold should err on the side of preservation and contact VHG's General Counsel or Calderwood & Harkness for guidance.
XII. Closing
We request that VHG provide written confirmation of its compliance with the instructions set forth in this letter within five (5) business days of receipt. Calderwood & Harkness stands ready to schedule a conference call or in-person meeting with VHG's legal, human resources, information technology, and payroll teams at the earliest practicable date to discuss the implementation of the litigation hold, the coordination of data collection and preservation activities, and any questions or concerns that may arise.
Calderwood & Harkness will continue to advise VHG on its preservation obligations as this matter develops, and will supplement the instructions in this letter as necessary in light of new information, changes in the scope of the threatened litigation, or the commencement of formal proceedings.
We appreciate VHG's commitment to fulfilling its preservation obligations and look forward to working closely with you and your team on this matter.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Bernard Crawford Responsible Partner, Labor & Employment Calderwood & Harkness LLP 100 Southeast Second Street, Suite 3400 Miami, Florida 33131 Telephone: (305) 884-7200
Email: bcrawford@calderwoodharkness.com
cc: (via email)
Theodore R. Langford, Chief Executive Officer, Verimark Hospitality Group Inc.
Marguerite A. Dunning, Chief Financial Officer, 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.
Renata Vasquez, Billing Partner, Calderwood & Harkness LLP
Nadia Petrov, Lead Associate, Calderwood & Harkness LLP
James Underwood, Working Associate, Calderwood & Harkness LLP
PRIVILEGED & CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION This letter and any attachments are privileged and confidential attorney-client communications prepared in anticipation of litigation. This letter is intended solely for the use of the addressee and the individuals copied above. Any unauthorized review, use, disclosure, distribution, or copying of this letter or its contents is strictly prohibited. If you have received this letter in error, please contact Calderwood & Harkness LLP immediately at (305) 884-7200.
Calderwood & Harkness LLP — Matter No. 1021-00005
No. | Property Name | Address | Rooms | Total Employees (approx.) | Hourly Employees (approx.)
1 | Verimark Regency Tampa | 1200 North Westshore Boulevard, Tampa, FL 33607 | 320 | 410 | 295
2 | Verimark Grand Orlando | 8750 International Drive, Orlando, FL 32819 | 485 | 580 | 420
3 | Verimark Shores Clearwater | 455 Mandalay Avenue, Clearwater Beach, FL 33767 | 210 | 260 | 190
4 | Verimark Bayfront St. Petersburg | 100 First Avenue South, St. Petersburg, FL 33701 | 275 | 340 | 245
5 | Verimark Resort & Spa Boca Raton | 2600 North Ocean Boulevard, Boca Raton, FL 33431 | 390 | 470 | 340
6 | Verimark Oceanview Fort Lauderdale | 3030 Holiday Drive, Fort Lauderdale, FL 33316 | 305 | 365 | 265
7 | Verimark Key West Collection | 1500 Reynolds Street, Key West, FL 33040 | 150 | 195 | 140

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