This document provides comprehensive, forensically documented supporting evidence for JWTC LLC's invoice to the City of Baltimore Department of Public Works for emergency snow and ice removal services performed January 31 – February 12, 2026. Every dollar on this invoice is traceable to a specific city directive.
| Fact | Evidence |
|---|---|
| The city directed every aspect of this operation | 68 documented authorizations from 7 city officials (Section 3) |
| The city knew exactly what was deployed — and didn't object | Equipment counts reported to Toya Sykes on 5 separate occasions (EVD-0038, EVD-0058) |
| The city defined scope to include dump trucks and salting | Toya: "This is a SNOW REMOVAL OPERATION" (EVD-0135, EVD-0138) |
| JWTC raised billing concerns — city never responded | 19 questions asked, most unanswered (Section 8) |
| City called JWTC crews "DPW CONTRACTORS" | Toya notified all salt domes (EVD-0116) |
| City was satisfied with the work | Steve post-demob: "all looks good" (EVD-0155) |
| Line Item | Amount |
|---|---|
| Total Processed Payroll (Sub Costs) | $11,205,354 |
| — Neiman Location | $5,967,988 |
| — M&T Stadium Location | $5,237,366 |
| Estimated Daily Burn Rate | ~$1.6M/day |
| Estimated Total Contract Value (City Owes) | ~$12.8M |
| Date | Event |
|---|---|
| Jan 31 | Contract negotiated, signed, and executed in a single day |
| Feb 1 | Operations commence — initial deployment issues (6 of 50 skid steers) |
| Feb 2 | City begins directing equipment movements via text (EVD-0121) |
| Feb 3 | 134 skid steers on site; QR tracking deployed; dump trucks ordered |
| Feb 4 | 236 skids, 44 dumps reported — no city objection; worker assaulted |
| Feb 5 | Amendment 1 sent (email/PDF mismatch); priority routes with deadlines |
| Feb 6 | Amendment 2 formally requested (salt trucks + supervisors) |
| Feb 7 | Amendment 1 fully executed; City Council begins driving scope |
| Feb 8 | Toya defines scope: "SNOW REMOVAL OPERATION" — dump trucks justified |
| Feb 9 | 295 skids, 81 dumps, 15 loaders, 10 salt — no objection; shooting incident |
| Feb 10-11 | Dozer requested; 340 dump loads in one day; dump site chaos |
| Feb 12 | City-ordered demob; Patrick raises billing concerns — no response |
| Feb 13 | Post-demob inspections: "all looks good" |
| Name | Title | Role in Operations | Authorizations |
|---|---|---|---|
| Kendall Abu-Hakim | Department Director | Executive authority | 1 |
| Toya Sykes | Chief, Fleet & Facilities | Primary operations commander | 39 |
| Steve Strickland | Chief, Ops & Logistics | Logistics lead | 17 |
| Sandra Calligan | Fleet Manager | Amendment management | 4 |
| Anthony Galloway | Division Manager | Route/dump truck direction | 4 |
| Alan D. Robinson | Deputy Director | Urgent priority clearing | 1 |
| Paris Gray | City Council Member | Political pressure / scope expansion | 1 |
| Element | Detail | Status |
|---|---|---|
| Original Contract | 204 skid steers @ $225/hr, 4 loaders @ $325/hr | ✅ Executed Jan 31 |
| Amendment 1 | 50 dump trucks @ $175/hr | ✅ Executed Feb 7 |
| Amendment 2 | Salt trucks @ $180/hr, Supervisors @ $125-150/hr | ⚠️ Never executed |
This section documents 68 specific instances where City of Baltimore officials directed, approved, acknowledged, or tacitly accepted JWTC's work.
| # | Date | Official | Action | Type | Evidence |
|---|---|---|---|---|---|
| 7 | Feb 3 | Toya Sykes | Receives 134 skid steers on site — no objection | T | EVD-0101 |
| 12 | Feb 4 | Toya Sykes | "I need a dump truck, skid steer, salt truck" | D | EVD-0030 |
| 15 | Feb 4 | Steve Strickland | "Lot B at M&T Stadium has been approved for staging" | D | EVD-0057 |
| 16 | Feb 4 | All Officials | Receive 236 skids, 44 dumps — no objection | T | EVD-0058 |
| 18 | Feb 4 | Toya Sykes | Notifies all salt domes: "they are DPW CONTRACTORS" | D | EVD-0116 |
| 40 | Feb 7 | A. Galloway | City Council (Paris Gray) → Abu-Hakim → Galloway → JWTC | D | EVD-0084 |
| 45 | Feb 8 | Toya Sykes | "This is a SNOW REMOVAL OPERATION" | D | EVD-0135 |
| 49 | Feb 9 | Toya Sykes | "We are REMOVING the snow... Make sure we are salting" | D | EVD-0138 |
| 51 | Feb 9 | Toya Sykes | "14 dumps 4 bobcats for your team" | D | EVD-0140 |
| 53 | Feb 9 | Toya Sykes | Receives 295 skids, 81 dumps, 15 loaders, 10 salt — NO OBJECTION | T | EVD-0038 |
| 58 | Feb 10 | Steve Strickland | "Can anyone advise if we have any dozer in theater?" | D | EVD-0143 |
| 65 | Feb 12 | Steve Strickland | Formal demob: "0700-1700 to demobilize" | D | EVD-0151 |
| 66 | Feb 12 | Steve Strickland | "Toya spoke to me about the second addendum" | A | EVD-0002 |
| 68 | Feb 13 | Steve Strickland | "all looks good" / "things are looking pretty good" | A | EVD-0155 |
| Equipment Type | Hourly Rate | Source | Status |
|---|---|---|---|
| Skid Steer (w/ operator) | $225/hr | Original Contract | ✅ Executed |
| Wheeled Loader | $325/hr | Original Contract | ✅ Executed |
| Dump Truck (10-ton, w/ driver) | $175/hr | Amendment 1 | ✅ Executed |
| Salt Truck | $180/hr | Amendment 2 (requested) | ⚠️ Never executed |
| Operations Supervisor | $150/hr | Amendment 2 (requested) | ⚠️ Never executed |
| Field Crew Supervisor | $125/hr | Amendment 2 (requested) | ⚠️ Never executed |
| Location | Operators | Hours | Amount |
|---|---|---|---|
| Neiman | ~1,924 | ~20,444 | $5,967,988 |
| M&T Stadium | ~977 | ~11,644 | $5,237,366 |
| TOTAL | ~32,088 | $11,205,354 |
| Date | Equipment Deployed | Est. Daily Billing |
|---|---|---|
| Feb 3 | 134 skids, ~18 dumps | ~$838,200 |
| Feb 4 | 236 skids, 44 dumps, 3 loaders | ~$1,482,600 |
| Feb 5-7 | Ramping to peak | ~$1.2M–$1.6M/day |
| Feb 9 (peak) | 295 skids, 81 dumps, 15 loaders, 10 salt | ~$2,093,400 |
| Feb 10-11 | Sustained peak | ~$1.8M–$2.0M/day |
| Feb 12 | Demob (0700-1700) | ~$200K+ |
| Date | Skid Steers | Dump Trucks | Loaders | Salt Trucks | Reported To | Response |
|---|---|---|---|---|---|---|
| Feb 3 | 134 | — | — | — | Toya | No objection |
| Feb 4 | 236 | 44 | 2-3 | — | All officials | No objection |
| Feb 9 | 295 | 81 | 15 | 10 | Toya | No objection |
| Equipment | Authorized | Actual (Feb 9) | Variance | % Over |
|---|---|---|---|---|
| Skid Steers | 204 | 295 | +91 | +44% |
| Dump Trucks | 50 | 81 | +31 | +62% |
| Wheel Loaders | 4 | 15 | +11 | +275% |
| Salt Trucks | 0 | 10 | +10 | N/A |
| Supervisors | 0 | 12 | +12 | N/A |
| Equipment | Requested By | Quote | Evidence |
|---|---|---|---|
| Dump Trucks | Toya Sykes | "I need a dump truck" | EVD-0030 |
| Salt Trucks | Toya Sykes | "2 salt trucks over at 1600 Northgate" | EVD-0134 |
| Wheeled Loader | Toya Sykes | "we need to bring a wheeled loader" | EVD-0032 |
| Lightning Loaders | Toya Sykes | "We need lightning loaders" | EVD-0067 |
| Dozer | Steve Strickland | "do we have any dozer in theater?" | EVD-0143 |
The scope expanded dramatically. Every expansion was driven by the city — not JWTC.
Toya Sykes, Feb 8: "This is a SNOW REMOVAL OPERATION. Creating piles is not apart of the contracted scope of work!" (EVD-0135)
Toya Sykes, Feb 9: "We are REMOVING the snow from these alleys. DO NOT BLOCK RESIDENTS IN... Make sure we are salting as well." (EVD-0138)
The scope wasn't just operationally driven — it was politically driven:
| Element | Sandra's Email (Feb 5) | Signed PDF (Feb 7) |
|---|---|---|
| Equipment | "50 skid steers" | "50 Dump Trucks" |
| Rate | Not stated | $175.00/hr |
| Legal Status | Cover email | Binding signed document |
| Date | Event | Evidence |
|---|---|---|
| Feb 6 | Charlene formally requests Amendment 2 | |
| Feb 7 | Sandra: "We are reviewing... will process it soon" | |
| Feb 12 | Steve: "Toya spoke to me about the second addendum" | EVD-0002 |
| Feb 12 | Operations conclude — Amendment 2 never executed | — |
| Equipment | First Deployed | Amendment Signed | Gap |
|---|---|---|---|
| Dump Trucks | Feb 3 | Feb 7 | 4 days |
| Salt Trucks | Feb 4 | Never | 9+ days |
| Supervisors | Feb 1 | Never | 12+ days |
JWTC raised 19 specific questions to DPW officials. Most were never answered.
| # | Date | Who Asked | Question | Directed To | Status |
|---|---|---|---|---|---|
| 1 | Feb 12 | Patrick | "Unit counts changed on the fly... Is that going to present an issue on billing?" | Steve | NO RESPONSE |
| 2 | Feb 12 | Patrick | "Please respond to my email this morning" | Steve | NO RESPONSE |
| 5 | Feb 6 | Charlene | Amendment 2 for salt trucks — addendum request | Sandra | NEVER EXECUTED |
| 8 | Feb 5 | Patrick | Towed truck resolution — $1,850 | Steve | NO RESOLUTION |
| 9 | Feb 9 | Patrick | Dozer/excavator clearance and pricing | Toya | NEVER RESOLVED |
| 11 | Feb 12 | Patrick | Written confirmation demob is complete | Steve | NEVER PROVIDED |
| 12 | Feb 12 | Patrick | Final timesheet reconciliation agreement | Steve | NEVER PROVIDED |
| 13 | Feb 12 | Patrick | Invoicing timeline through Workday | Steve | NEVER PROVIDED |
| Direction | Request Type | Response Time |
|---|---|---|
| City → JWTC | Equipment deployment | Minutes to hours |
| City → JWTC | Press conference numbers | "Not a minute late" |
| JWTC → City | Billing clarification | NEVER |
| JWTC → City | Amendment 2 execution | 7+ days → NEVER |
| JWTC → City | Demob sign-off items | NEVER |
JWTC crews operated 24/7 in dangerous Baltimore neighborhoods during freezing winter conditions. Ten safety incidents were documented.
| Date | Location | Incident | Evidence |
|---|---|---|---|
| Feb 4 | W Lexington / N Poppleton | Gun incident — screenshot forwarded to Toya | EVD-0041 |
| Feb 5 | Undisclosed | Gun pulled on crew — evacuated, cussed at on return | EVD-0063 |
| Feb 9 | City streets | Police prioritization failure — Patrick couldn't get police support | — |
| Activity | City (DPW) | JWTC | What This Means |
|---|---|---|---|
| What equipment to deploy | A / R | I | City told JWTC what to send |
| How many units | A / R | I | Changed "on the fly" by DPW |
| Where to stage | A / R | I | 5 staging sites — all city-directed |
| Where to dump snow | A / R | I | 9+ dump sites — all city-managed |
| Which routes to clear | A / R | I | Specific addresses and deadlines |
| Scope definition | A / R | I | "SNOW REMOVAL" — city's words |
| Operating schedule | A / R | I | 24-hour ops; demob timing |
| Amendment execution | A / R | C | DPW drafted; JWTC requested |
| Executing field work | I | R | JWTC performed the work |
| Tracking hours | I | R | JWTC + City QR system |
| Raising billing concerns | — | R | JWTC flagged; city didn't respond |
| Rank | Ref | Date | Description |
|---|---|---|---|
| 1 | EVD-0038 | Feb 9 | Toya receives 295/81/15/10 counts — no objection |
| 2 | EVD-0135 | Feb 8 | Toya: "This is a SNOW REMOVAL OPERATION" |
| 3 | EVD-0138 | Feb 9 | Toya: "REMOVING the snow... salting as well" |
| 4 | EVD-0010 | Feb 12 | Patrick raises billing concern — city never responds |
| 5 | EVD-0116 | Feb 4 | Toya: "they are DPW CONTRACTORS" |
| 6 | EVD-0151 | Feb 12 | Steve: formal demob directive |
| 7 | EVD-0002 | Feb 12 | Steve confirms Amendment 2 was city's responsibility |
| 8 | EVD-0058 | Feb 4 | 236/44 reported — no objection from any official |
| 9 | EVD-0155 | Feb 13 | Steve: "all looks good" |
| 10 | EVD-0140 | Feb 9 | Toya allocates: "14 dumps 4 bobcats for your team" |
| Date | Official | Quote |
|---|---|---|
| Feb 4 | Toya | "I love this!!!!" (Snow Flow Dashboard) |
| Feb 4 | Toya | "Thank you and your guys. I truly appreciate the help. I am grateful." |
| Feb 5 | Steve | "Nice work. You guys keep safe and warm." |
| Feb 6 | Sandra | "You guys are gettin' it done!" |
| Feb 8 | Toya | "You guys are ROCKSTARS!!!" |
| Feb 13 | Steve | "all looks good" / "things are looking pretty good" |
| Thread | Participants | Dates | Key Value |
|---|---|---|---|
| T1/T2 | Patrick ↔ Steve | Feb 5-12 | Amendment 2 confirmed; billing discrepancy |
| T3 | Patrick ↔ Toya | Feb 3-9 | Equipment counts, shooting, city directives |
| T4 | 7-person group | Feb 4-8 | Main ops group; M&T staging; towed truck |
| T5 | Patrick → Kendall | Feb 7 | DPW Director engagement |
| T6 | Galloway + subs | Feb 5-7 | City Council directives; dump truck requests |
| T7 | Patrick, Sandra, Toya | Feb 5 | Contract/reconciliation requests |
| T8 | 6-person group | Feb 3-4 | Earliest thread — QR system, salt, assault |
| T10 | 8-person group | Feb 6-13 | Demob, scope definition, dozer, dump sites |
This section anticipates 10 arguments the city could make — and documents JWTC's defense for each.
Prepared for use in mediation, dispute resolution, or litigation. Approximately 5-minute presentation.
In late January 2026, Baltimore was buried by a massive snowstorm. The city was desperate. DPW reached out to JWTC — a national emergency services contractor — and the entire contract was negotiated, signed, and executed in a single day: January 31st.
What followed was 12 days of the most intense, dangerous emergency operations this contractor has ever performed.
The city ran this operation. Not JWTC.
From Day 2, Toya Sykes — DPW's Chief of Fleet and Facilities — was texting Patrick Haygood telling him where to send equipment, what to deploy, and when. She deployed the city's QR check-in tracking system. She established reporting schedules. She told JWTC crews where to stage, where to dump snow, and what routes to clear.
She even told other city departments that JWTC crews were "DPW contractors" — her exact words — so that salt domes would stop denying them salt.
The scope expanded because the city expanded it.
The original contract was for skid steers to clear snow. But when Toya inspected the routes and found snow piles, she didn't say "good job." She said: "This is a SNOW REMOVAL OPERATION. Creating piles is not part of the contracted scope of work!" She repeated it the next day: "We are REMOVING the snow. Make sure we are salting as well."
Removal requires dump trucks. Salting requires salt trucks. The city's own scope definition mandated the equipment JWTC provided.
The city knew exactly what was deployed.
On February 9th, Toya personally requested a full equipment breakdown. Patrick provided it: 295 skid steers, 81 dump trucks, 15 wheel loaders, 10 salt trucks. Toya received those numbers. She didn't say "that's too many." She continued directing operations and that same day allocated "14 dumps and 4 bobcats" to a single team.
JWTC's people were shot at, beaten, and threatened.
On February 4th, a worker was assaulted and hospitalized in a medically induced coma with bilateral jaw fractures. On February 9th, a skid steer was struck by a bullet. The city knew. Their response: keep working.
When JWTC raised financial concerns, the city went silent.
On demobilization day, Patrick raised the billing discrepancy between field-directed counts and amendment counts. Steve never responded. Amendment 2 — covering salt trucks and supervisors — was requested on February 6th. The city acknowledged it, promised to process it, confirmed it was being handled. It was never executed.
The pattern is unmistakable.
The city demanded instant compliance when they wanted something. When JWTC needed contractual clarity, the city either delayed or never responded. Every dollar on JWTC's invoice traces to a specific directive from a city official. Sixty-eight documented authorizations from seven officials.
The city was satisfied. Steve inspected the sites and said they looked "pretty good." Toya called the crews "ROCKSTARS."
The city made the calls. JWTC made it happen. Now it is time to pay the bill.
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 January 31 – February 12, 2026.
JWTC LLC
Date: _______________
Date: _______________