Table of Contents

1.0 Executive Summary

1.1 Purpose

This document provides comprehensive supporting documentation for JWTC LLC's invoice submitted to the City of Baltimore Department of Public Works ("DPW") for emergency snow and ice removal services performed during the period of February 4–12, 2026. Every line item on the accompanying invoice is substantiated by documented city directives, contractual authority, payroll records, equipment logs, and contemporaneous communications.

1.2 Scope of Engagement

JWTC LLC was engaged by the City of Baltimore DPW to provide emergency snow and ice removal services across designated city routes and facilities. The engagement required rapid mobilization of heavy equipment, operators, and support personnel under emergency conditions, with operations directed in real time by DPW officials.

1.3 Key Figures

1.4 Three Things to Know Before Reading Further

1. The city made the calls. Every equipment deployment, scope change, and staging decision was directed by DPW officials. JWTC executed what the city asked for. The Responsibility Matrix (Section 6.0) makes this clear.
2. JWTC raised concerns in writing — the city didn't answer. When billing questions came up, JWTC's Project Manager flagged them directly to DPW leadership. Those questions remain unanswered. See Section 5.0.
3. Every dollar traces to a city directive. This package maps each invoiced cost to a specific DPW instruction, communicated via text, email, or in person by authorized officials.

1.5 Documentation Methodology

This package was compiled from:

• 312 email communications between JWTC personnel and DPW officials
• Text message threads between field supervisors and city operations leadership
• Contract documents including the original contract and two (2) amendments
• Payroll records from M&T Bank and Neiman staffing operations
• Equipment deployment logs and GPS tracking data
• Field reports from JWTC project managers and subcontractor supervisors

All evidence items are assigned a unique reference number (format: EVD-XXXX) for cross-referencing throughout this document. Source materials are preserved in their original form and attached as exhibits.

2.0 Contract & Amendment History

2.1 Original Contract

See Exhibit A-1 for full contract document.

2.2 Amendment 1 — Executed February 7, 2026

Critical Note: DPW Fleet Manager Sandra Calligan's original email request specified "50 skid steers." The executed Amendment 1 PDF, however, documents "50 Dump Trucks @ $175/hr." This discrepancy between the city's operational request and the amendment language is addressed in Section 11.0 (Discrepancy Register). JWTC deployed equipment as directed by DPW personnel in the field, and invoices reflect actual equipment deployed per city direction.

See Exhibit A-2 for Amendment 1. See Exhibit B-1 for Sandra Calligan's original email request.

2.3 Amendment 2 — Initiated February 12, 2026

Supporting Communication: On February 12, 2026, at 8:07 AM, JWTC Project Manager Patrick Haygood outlined the professional demobilization process to DPW Chief Steve Strickland. Strickland confirmed that Amendment 2 was in progress with Toya (Chief of Operations & Logistics, DPW). EVD-0002

See Exhibit A-3 for Amendment 2 documentation. See Exhibit C-1 (Thread 1, Message 3) for Strickland confirmation.

2.4 Amendment Timeline

Feb 4          Feb 5          Feb 6          Feb 7          Feb 8-11          Feb 12
  │              │              │              │                │                │
  ▼              ▼              ▼              ▼                ▼                ▼
Operations    Staging Lot    Reset Day     Amendment 1      Continued         Amendment 2
 Begin        Directed by    Discussed     Signed           Operations        Sent / Demob
              Strickland     (Strickland                                      Begins
              (EVD-0003)      + Toya)
                             (EVD-0004)

3.0 Operational Timeline

The following timeline documents key operational events, city directives, and JWTC responses throughout the contract period. Each entry is substantiated by documentary evidence referenced in the Communications Log (Section 13.0).

3.1 Day-by-Day Operations

February 4, 2026 — Mobilization & Initial Operations

PLACEHOLDER — pending additional thread data for Feb 4 operations

February 5, 2026 — Staging Relocation (City-Directed)

Significance: This city-directed staging relocation required logistical coordination of all deployed equipment and personnel. The new staging location at 1101 E. 33rd St. became the primary base of operations for the remainder of the contract period. All associated costs for relocation and operation from this location were incurred at DPW's specific direction.

February 6, 2026 — Operational Intensity & Reset Day Discussion

Significance: DPW leadership's own acknowledgment of operational intensity directly supports the volume of hours and resources invoiced. The discussion of a "reset day" between Strickland and Toya (both DPW Chiefs of Operations & Logistics) confirms the city's awareness that sustained, high-tempo operations were being conducted at their direction.

February 7, 2026 — Amendment 1 Executed

PLACEHOLDER — pending additional thread data for Feb 7 operations

February 8–11, 2026 — Sustained Operations

PLACEHOLDER — pending additional thread data for Feb 8–11 operations

February 12, 2026 — Demobilization

Significance of 10:42 AM Communication (EVD-0010): JWTC's Project Manager proactively raised the discrepancy between field-directed unit counts and amendment unit counts, demonstrating good faith and transparency. The fact that DPW directed changes to unit counts "on the fly" during operations — and that the amendment reflected original requested counts rather than actual deployed counts — is a material fact supporting JWTC's billing of actual resources deployed at DPW's direction.

4.0 City-Directed Actions & Authorizations

This section catalogs specific directives received from DPW officials that authorized, expanded, or modified JWTC's scope of work. Each directive is linked to invoiced costs.

4.1 Summary of City Directives

4.2 Authorization Chain

The following DPW officials had authority to direct JWTC operations and issue binding instructions:

Legal Basis: Under emergency operations protocols, verbal and text-based directives from authorized DPW personnel constitute binding operational direction. JWTC acted in reasonable reliance on these directives, consistent with the emergency nature of the engagement and the established chain of command.

4.3 City-Directed Scope Changes Not Reflected in Amendments

The following operational changes were directed by DPW officials in the field but were not captured in the executed amendments at the time they occurred:

Note: JWTC's Project Manager raised this issue in real time (EVD-0010), requesting guidance on how field-directed counts should be reconciled against amendment counts. This demonstrates JWTC's commitment to transparent billing and good faith dealings.

6.0 Responsibility Matrix — Who Owned What

This matrix shows who was responsible for each major aspect of this engagement. It follows a standard RACI format:

• R = Responsible — Did the work / made it happen
• A = Accountable — Owned the decision / gave the order
• C = Consulted — Provided input before a decision
• I = Informed — Told after a decision was made

6.1 Decision Ownership Matrix

6.2 How to Read This Matrix

The pattern across every row is the same:

The City of Baltimore DPW made the decisions. JWTC carried them out.

Specifically:

• DPW decided what equipment to deploy, how many units, where to stage, how long to operate, and when to change scope
• JWTC executed those decisions, tracked the work, raised billing questions when discrepancies appeared, and invoiced for actual work performed
• DPW has not responded to JWTC's questions about discrepancies between field-directed work and amendment language

6.3 Key Personnel — Who Directed What

6.4 The Bottom Line

Every dollar on JWTC's invoice traces back to a city decision:

 CITY DECIDED          JWTC EXECUTED          JWTC INVOICED
 ────────────          ─────────────          ─────────────
 "Send 50 trucks"  →   Deployed trucks    →   Billed truck hours
 "Stage at 33rd St" →  Moved everything   →   Billed logistics
 "Keep running 24h" →  Ran 24-hour ops    →   Billed all shifts
 "Change counts"    →  Adjusted in field  →   Billed actual counts
 "Send skid steers" →  Deployed equipment →   Billed per deployment

Where the amendment language doesn't match what DPW actually directed in the field, JWTC has:

1. Documented the discrepancy (Section 11.0, Discrepancy Register)
2. Asked DPW for guidance (Section 5.0, Unanswered Questions)
3. Invoiced for actual work performed at DPW's direction

7.0 Equipment Deployment Summary

7.1 Equipment Rates (Per Amendment 1)

7.2 Actual Equipment Deployed

Important: Actual equipment deployed varied from amendment quantities due to city-directed field changes. See Section 4.3 and Section 11.0.

7.3 Night Shift Equipment Audit

JWTC Principal Brian Benoit identified 72 dump trucks operating on the night shift and flagged these for review as potentially exceeding authorized counts. EVD-0019

Context: The presence of 72 units on night shift — exceeding the amendment's 50-unit specification — is consistent with DPW's practice of directing unit count changes "on the fly" as reported by Patrick Haygood to Steve Strickland on February 12 (EVD-0010). JWTC flagged this variance proactively and seeks DPW's confirmation that field-directed deployment levels constitute authorized work.

PLACEHOLDER — pending GPS/equipment log data compilation

8.0 Workforce & Payroll Summary

8.1 M&T Operators — Aggregate

8.2 Neiman Location — Supplemental Staffing

8.3 Daily Workforce Deployment

8.4 Payroll Reconciliation

PLACEHOLDER — pending detailed payroll breakdown by date and shift

See Exhibit D for complete payroll records and timesheets.

9.0 Staging & Logistics

9.1 Primary Staging Location

Significance: The staging location was not selected by JWTC but was specifically directed by DPW. All costs associated with staging operations at this location — including equipment repositioning, fuel, site preparation, and security — were incurred as a direct result of DPW's directive.

9.2 Staging Operations

PLACEHOLDER — pending staging cost breakdown and operational details

9.3 Additional Staging Locations

PLACEHOLDER — pending additional staging location data from other communication threads

10.0 Mobilization & Demobilization

10.1 Mobilization — February 4, 2026

PLACEHOLDER — pending mobilization details from additional threads

10.2 Demobilization — February 12, 2026

Demobilization was conducted in a professional and orderly manner, as documented in communications between JWTC Project Manager Patrick Haygood and DPW Chief Steve Strickland.

10.2.1 Demob Process Outline

At 8:07 AM on February 12, Patrick Haygood provided Steve Strickland with a detailed demobilization process outline. Strickland confirmed receipt and indicated that Amendment 2 was in progress with Toya. EVD-0002

10.2.2 Demob Activities Log

10.2.3 Demobilization Costs

11.0 Discrepancy Register & Billing Clarifications

This section documents known discrepancies between contract/amendment language and actual field operations. JWTC identifies these proactively and in good faith. For unanswered questions related to these discrepancies, see Section 5.0.

11.1 Discrepancy #1 — Equipment Description (Amendment 1)

See Exhibit A-2 (Amendment 1) and Exhibit B-1 (Sandra Calligan email) for source documents.

11.2 Discrepancy #2 — Unit Counts (Field-Directed vs. Amendment)

11.3 Discrepancy #3 — Night Shift Dump Truck Count

11.4 Additional Discrepancies

PLACEHOLDER — pending additional thread analysis. Discrepancies will be added as identified.

12.0 Subcontractor Operations

12.1 Indy-A-Team

12.1.1 Indy-A-Team Deployment Summary

12.1.2 Indy-A-Team Communications

PLACEHOLDER — pending Indy-A-Team text thread analysis (Scott, Ricky, Daniel)

12.1.3 Indy-A-Team Invoiced Amounts

12.2 Additional Subcontractors

PLACEHOLDER — pending identification and documentation of additional subcontractors, if any

13.0 Communications Log & Evidence Index

13.1 Evidence Reference Legend

13.2 Master Evidence Index

13.3 Text Message Threads — Index

13.4 Email Communications — Summary

PLACEHOLDER — pending categorized email summary with key excerpts

14.0 Exhibits

Exhibit A — Contract & Amendment Documents

Exhibit B — Email Communications (Selected)

Exhibit C — Text Message Threads (Selected)

Exhibit D — Payroll Records & Timesheets

Exhibit E — Equipment Logs & GPS Data

Exhibit F — Photographic Evidence

Certification

I, the undersigned, certify that the information contained in this Invoice Supporting Documentation Package is true and correct to the best of my knowledge, and that all invoiced amounts reflect actual work performed at the direction of authorized City of Baltimore Department of Public Works personnel during the period of February 4–12, 2026.