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 2–12, 2026. Every line item on the accompanying invoice is substantiated by documented city directives, contractual authority, payroll records, equipment logs, and contemporaneous communications drawn from 312 emails and 10 text message threads comprising 500+ messages.

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 including Chief Toya Sykes, Chief Steve Strickland, Fleet Manager Sandra Calligan, Division Manager Anthony Galloway, and Department Director Kendall Abu-Hakim.

1.3 Key Figures

1.4 Three Things to Know Before Reading Further

1. The city made the calls. Every equipment deployment, scope change, staging decision, and route assignment was directed by DPW officials. JWTC executed what the city asked for. The Responsibility Matrix (Section 6.0) makes this unambiguous.
2. JWTC raised concerns in writing — the city didn't answer. When billing questions arose, JWTC's Project Manager flagged them directly to DPW leadership. Those questions remain unanswered as of the date of this package. 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. 87 individual evidence items are catalogued in Section 13.0.

1.5 Documentation Methodology

This package was compiled from:

• 312 email communications between JWTC personnel and DPW officials
• 10 text message threads (~500+ messages) between field supervisors and city operations leadership, OCR-extracted from PDF exports via Google Document AI
• Contract documents including the original agreement and Amendment 1 (executed) and Amendment 2 (in progress)
• Payroll records from M&T Bank and Neiman Avenue staffing operations
• Equipment deployment logs and QR code check-in system data (city-created)

All evidence items are assigned a unique reference number (format: EVD-XXXX) and discrepancies use DISC-XXX for cross-referencing throughout this document.

2.0 Contract & Amendment History

2.1 Original Contract

2.2 Amendment 1 — Executed February 7, 2026

⚠ Critical Discrepancy (DISC-001): Sandra Calligan's cover email stated "Please see the attached amendment to the contract for the 50 skid steers." The attached executed PDF, however, clearly documents "50 Dump Trucks @ $175/hr." The signed legal document controls. See Section 11.0 for full analysis.

2.3 Amendment 2 — In Progress as of February 12, 2026

2.4 Equipment Rate Schedule

2.5 Amendment Timeline

Jan 31        Feb 1         Feb 3          Feb 5          Feb 7          Feb 12
  │             │             │              │              │               │
  ▼             ▼             ▼              ▼              ▼               ▼
Contract      Ops Begin     Patrick        Amendment 1    Amendment 1    Amendment 2
Signed        (6 of 50      requests       PDF sent       Fully          Confirmed
(same day)    skids show)   dump truck     by Sandra      Executed       in progress
                            amendment                                    by Steve
                            to Sandra                                    (EVD-0002)

3.0 Operational Timeline

The following day-by-day timeline documents key operational events, city directives, and JWTC responses. Each entry is substantiated by evidence referenced in Section 13.0.

3.1 February 2 — Day 2 (Post-Contract)

3.2 February 3 — Day 3 (QR System, Salt Denied, Staging Changes)

3.3 February 4 — Day 4 (M&T Staging, Worker Assault, 236 Skids)

3.4 February 5 — Day 5 (Gun Pulled, New Staging, Contract Urgency)

3.5 February 6 — Day 6 (Loader Request, Salt Denied Again, "Reset Day")

3.6 February 7 — Day 7 (Amendment 1 Executed, City Council Requests)

3.7 February 8 — Day 8 ("SNOW REMOVAL OPERATION")

3.8 February 9 — Day 9 (THE BIG DAY — Shooting, 295 Skids, Scope Defined)

3.9 February 10–11 — Days 10–11 (Dozer, Dump Site Chaos, 340 Loads)

3.10 February 12 — Day 12 (Demobilization)

3.11 February 13 — Post-Demob Inspection

4.0 City-Directed Actions & Authorizations

This section catalogs the 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 Staging Location Directives

Every staging location was city-directed. JWTC did not choose where to stage — the city told them.

4.2 Equipment Deployment Directives

4.3 Scope Definition Directives

Feb 8, 11:57 AM — Toya Sykes (DPW Chief):
"This is a SNOW REMOVAL OPERATION. Creating piles is not apart of the contracted scope of work! I want the piles gone." EVD-0135

Feb 9, 8:59 AM — Toya Sykes (DPW Chief):
"We are REMOVING the snow from these alleys. DO NOT BLOCK RESIDENTS IN or leave any piles of snow in the alleys. Our Trash and Recycling trucks must be able to get through. Make sure we are salting as well." EVD-0138

Legal Significance: Toya's own words define the contracted scope as snow removal — not merely snow pushing. Full removal requires dump trucks to haul snow away. Salting requires salt trucks. These directives from the city's Chief of Operations justify every dump truck and salt truck hour on JWTC's invoice.

4.4 Route & Priority Directives

DPW officials directed JWTC to specific routes, addresses, and neighborhoods — often driven by constituent complaints and City Council requests. Examples include:

• Sandra directing Routes 1206/1207 + urgent 1423 Walker Ave (disabled child, DPW Deputy Director request) EVD-0060 EVD-0081
• Toya directing Woodbourne Rd by 8pm deadline EVD-0061
• Toya directing crew to 2700 Ellicott Dr (elderly disabled resident) EVD-0052
• Toya directing 1600 Northgate Rd — "clear entire alley and all alleys" EVD-0133
• City Council member Paris Gray directing work through DPW Director EVD-0084

4.5 Authorization Chain

6.0 Responsibility Matrix — Who Owned What

This matrix shows who was responsible for each major aspect of this engagement. R = Responsible (did the work), A = Accountable (owned the decision), C = Consulted, I = Informed.

6.1 The Bottom Line

 CITY DECIDED          JWTC EXECUTED          JWTC INVOICED
 ────────────          ─────────────          ─────────────
 "Send 295 skids"  →   Deployed equipment  →   Billed actual counts
 "Stage at M&T"    →   Moved everything    →   Billed logistics
 "REMOVE the snow" →   Deployed dump trucks→   Billed truck hours
 "Send salt trucks"→   Deployed 10 salt    →   Billed salt hours
 "Get a dozer"     →   Brought dozer       →   Billed dozer time
 "Demob 0700-1700" →   Professional demob  →   Billed through window

7.0 Equipment Deployment Summary

7.1 Equipment Count Trajectory — Reported to City

7.2 Variance Analysis (Feb 9 Actuals vs. Authorized)

The city received these numbers and took no corrective action. Toya asked for the counts, received them, and raised zero objections. She asked a second time later the same day EVD-0040 — still no objection. The city's senior operations official implicitly authorized these deployment levels through informed acceptance.

7.3 Night Shift Equipment Audit

JWTC Principal Brian Benoit identified 72 dump trucks operating on a single night shift at Neiman on Feb 9. This exceeds the Amendment 1 authorized count of 50 by 44%. This is consistent with the overall pattern of field-directed deployment exceeding amendment quantities DISC-003.

7.4 Toya's Personal Equipment Allocation

DPW Chief Toya Sykes was not merely informed of equipment counts — she was actively distributing equipment:

"Scott.... I have 14 dumps 4 bobcats for your team. Where are they going?" EVD-0140

This demonstrates the city controlled equipment allocation at the individual unit level.

8.0 Workforce & Payroll Summary

8.1 M&T Stadium Operators — Payroll Period 2 (Feb 4–10)

8.2 Neiman Avenue — Payroll Period 2 (Feb 4–9)

8.3 Combined Workforce Confirmation

On February 9, DPW Chief Toya Sykes asked how many people were at M&T and Neiman for food truck logistics. Patrick responded: "450" EVD-0043. The city arranged food trucks for this workforce — acknowledging the scale of operations and treating JWTC crews as their own.

8.4 Payroll Rate Correction (Feb 12)

Lindsey requested equipment-specific rates be applied to payroll calculations. After correction:

9.0 Staging & Logistics

9.1 City-Directed Staging Locations

9.2 City-Controlled Dump Sites

9.3 Salt Dome Access Issues

JWTC salt trucks were denied access to city-owned salt domes at least three times:

1. Feb 3: Refused salt at designated location. Toya resolved: "5...4...3...2..1 now" EVD-0105
2. Feb 4: Salt dome unstaffed. Sandra: "DOT is getting someone there." Toya: "they are DPW CONTRACTORS" EVD-0115 EVD-0116
3. Feb 6: 4401 Leland Ave refusing to distribute salt — third denial EVD-0131

Each salt access denial was the city's internal communication failure, not JWTC's fault. Any salt truck downtime resulting from these denials was city-caused.

10.0 Mobilization & Demobilization

10.1 Mobilization Timeline

10.2 Demobilization — February 12, 2026

10.2.1 Formal Demob Directive

Steve Strickland (DPW Chief):
"We are using the current operational period (0700-1700) Thursday February 12th to demobilize. Field operation can conclude at this time. Please use this operation period as time to get any snow dump locations and staging areas organized and neat. Especially M&T lot B." EVD-0151

10.2.2 Demob Activities

10.2.3 Post-Demob Inspection (Feb 13)

Steve Strickland personally drove all sites on February 13:

• Loch Raven & 33rd: "all looks good" EVD-0155
• M&T Stadium: "things are looking pretty good" EVD-0155

Remaining equipment (2 trucks with trailers, bobcats, service truck) was being managed for pickup. Steve: "No rush." The city was satisfied with demobilization execution.

10.2.4 Professional Punch List

Patrick proactively identified and committed to resolving property damage:

• Garage door repair
• Fence repair
• Porta toilet removal
• Staging area cleanup

"It's not just about moving machines, it's about making sure we tie up those loose ends without the city or our name tarnished for failure to see small details through." — Patrick Haygood, JWTC PM

11.0 Discrepancy Register & Billing Clarifications

JWTC identifies these discrepancies proactively and in good faith. For unanswered questions related to these discrepancies, see Section 5.0.

Pattern: Every discrepancy is either (a) caused by the city's internal processes or (b) the result of city-directed field operations outpacing the city's own amendment process. In no case did JWTC unilaterally expand scope.

12.0 Subcontractor Operations

12.1 Indy-A-Team

12.2 Supervisor Payments

Field Crew Supervisors were paid at $550/day flat rate (billed to City at $125/hr = $3,000/day, yielding 63.3% margin on this line item).

12.3 ACH Payments to Subcontractors

12.4 Subcontractor Crew Lead Roster

JWTC deployed over 15 subcontractor companies with designated day and night shift leads. Key companies included:

• Midwest Industrial, Slave Driver LLC, Musick Trucking, Local Buckets
• Dove, Area Consulting, Cornerstone Excavation, Asset Management
• Smith Excavating, Don's Does It, 2 Eagle Trucking, Eagle Rock Hauling
• King Trucking, Hearing Tree, All Year Round Tree, Western Excavation
• Blackwater Fleet, Best Choice Fence, ReclaimIt Enterprises

All subs checked in under the JWTC name in the city's QR system EVD-0109, consistent with the prime contractor billing structure. Toya referred to all personnel as "DPW CONTRACTORS" EVD-0116.

13.0 Communications Log & Evidence Index

13.1 Evidence Summary

13.2 Top 5 Evidence Items

13.3 Text Message Thread Index

13.4 Email Communications

312 emails analyzed across brian@jwtc.net, brian@phaseone.consulting, and related accounts. Key email threads cover:

• Contract negotiation and execution (Jan 31)
• Amendment 1 signing (Feb 5–7) — including the critical email/document mismatch
• Amendment 2 request and DPW's "reviewing" response (Feb 6–7)
• Payroll data, check-in reconciliation, and rate corrections
• Brian Benoit's "Financial Risk" email (Feb 8) identifying $1.4M/day exposure
• Snow Flow app deployment and QC portal credentials
• Demobilization planning and punch list

14.0 Exhibits

Exhibit A — Contract & Amendment Documents

Exhibit B — Email Communications (Selected)

Exhibit C — Text Message Threads

Exhibit D — Payroll Records & Timesheets

Exhibit E — Equipment Logs & GPS Data

Exhibit F — Photographic & Video 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 2–12, 2026.

This package documents 87 individual evidence items drawn from 312 emails and 10 text message threads comprising 500+ messages. Every cost traces to a city directive. Every discrepancy was flagged by JWTC. Every unanswered question remains the city's responsibility.

JWTC LLC

Brian Benoit

Owner / Principal, JWTC LLC

Date: _______________

Patrick Haygood

Project Manager, JWTC LLC

Date: _______________