VERSION 2.0 — FORENSIC EVIDENCE UPDATE
Invoice Supporting
Documentation Package
City of Baltimore Department of Public Works
Emergency Snow & Ice Removal Operations
Period of Performance: January 31 – February 12, 2026
Prepared By: JWTC LLC — Brian Benoit, Principal
Document Reference: JWTC-BAL-SNOW-2026-002
Date: February 14, 2026

Table of Contents

1Executive Summary
2Project Overview
3City Authorization Chain NEW — 68 Authorizations
4Financial Summary
5Equipment Deployment Record
6Scope Evolution Timeline
7Amendment Analysis
8Unanswered Questions Register NEW — 19 Questions
9Contradiction Register NEW — 8 Contradictions
10Safety & Working Conditions 10 Incidents
11Responsibility Matrix (RACI)
12Evidence Index — 87+ Items
13Vulnerability Assessment & Rebuttals NEW — 10 Scenarios
14Case Narrative NEW
1
Executive Summary

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.

68 City Authorizations
$12.8M Estimated Contract Value
87+ Evidence Items
19 Unanswered Questions
8 City Contradictions
12 Days of Operations

1.1 The Core Facts

FactEvidence
The city directed every aspect of this operation68 documented authorizations from 7 city officials (Section 3)
The city knew exactly what was deployed — and didn't objectEquipment counts reported to Toya Sykes on 5 separate occasions (EVD-0038, EVD-0058)
The city defined scope to include dump trucks and saltingToya: "This is a SNOW REMOVAL OPERATION" (EVD-0135, EVD-0138)
JWTC raised billing concerns — city never responded19 questions asked, most unanswered (Section 8)
City called JWTC crews "DPW CONTRACTORS"Toya notified all salt domes (EVD-0116)
City was satisfied with the workSteve post-demob: "all looks good" (EVD-0155)

1.2 Financial Overview

Line ItemAmount
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
CITY DECIDED JWTC EXECUTED CITY OWES
──────────────────────────────────────────────────
"Send 295 skid steers" Deployed them Billed @ $225/hr
"We need dump trucks" Deployed 81 Billed @ $175/hr
"Make sure we're salting" Deployed 10 salt trucks Billed @ $180/hr
"Stage at M&T" Moved everything Billed logistics
"Run 24-hour ops" Ran 24-hour ops Billed all shifts
"This is SNOW REMOVAL" Removed snow Billed every load
2
Project Overview

2.1 Timeline

DateEvent
Jan 31Contract negotiated, signed, and executed in a single day
Feb 1Operations commence — initial deployment issues (6 of 50 skid steers)
Feb 2City begins directing equipment movements via text (EVD-0121)
Feb 3134 skid steers on site; QR tracking deployed; dump trucks ordered
Feb 4236 skids, 44 dumps reported — no city objection; worker assaulted
Feb 5Amendment 1 sent (email/PDF mismatch); priority routes with deadlines
Feb 6Amendment 2 formally requested (salt trucks + supervisors)
Feb 7Amendment 1 fully executed; City Council begins driving scope
Feb 8Toya defines scope: "SNOW REMOVAL OPERATION" — dump trucks justified
Feb 9295 skids, 81 dumps, 15 loaders, 10 salt — no objection; shooting incident
Feb 10-11Dozer requested; 340 dump loads in one day; dump site chaos
Feb 12City-ordered demob; Patrick raises billing concerns — no response
Feb 13Post-demob inspections: "all looks good"

2.2 Key Parties — City of Baltimore DPW

NameTitleRole in OperationsAuthorizations
Kendall Abu-HakimDepartment DirectorExecutive authority1
Toya SykesChief, Fleet & FacilitiesPrimary operations commander39
Steve StricklandChief, Ops & LogisticsLogistics lead17
Sandra CalliganFleet ManagerAmendment management4
Anthony GallowayDivision ManagerRoute/dump truck direction4
Alan D. RobinsonDeputy DirectorUrgent priority clearing1
Paris GrayCity Council MemberPolitical pressure / scope expansion1

2.3 Contract Structure

ElementDetailStatus
Original Contract204 skid steers @ $225/hr, 4 loaders @ $325/hr✅ Executed Jan 31
Amendment 150 dump trucks @ $175/hr✅ Executed Feb 7
Amendment 2Salt trucks @ $180/hr, Supervisors @ $125-150/hr⚠️ Never executed
3
City Authorization Chain NEW

This section documents 68 specific instances where City of Baltimore officials directed, approved, acknowledged, or tacitly accepted JWTC's work.

49 Direct Orders (D)
9 Explicit Approvals (A)
10 Tacit / Knowledge (T+K)

3.1 Selected Key Authorizations

#DateOfficialActionTypeEvidence
7Feb 3Toya SykesReceives 134 skid steers on site — no objectionTEVD-0101
12Feb 4Toya Sykes"I need a dump truck, skid steer, salt truck"DEVD-0030
15Feb 4Steve Strickland"Lot B at M&T Stadium has been approved for staging"DEVD-0057
16Feb 4All OfficialsReceive 236 skids, 44 dumps — no objectionTEVD-0058
18Feb 4Toya SykesNotifies all salt domes: "they are DPW CONTRACTORS"DEVD-0116
40Feb 7A. GallowayCity Council (Paris Gray) → Abu-Hakim → Galloway → JWTCDEVD-0084
45Feb 8Toya Sykes"This is a SNOW REMOVAL OPERATION"DEVD-0135
49Feb 9Toya Sykes"We are REMOVING the snow... Make sure we are salting"DEVD-0138
51Feb 9Toya Sykes"14 dumps 4 bobcats for your team"DEVD-0140
53Feb 9Toya SykesReceives 295 skids, 81 dumps, 15 loaders, 10 salt — NO OBJECTIONTEVD-0038
58Feb 10Steve Strickland"Can anyone advise if we have any dozer in theater?"DEVD-0143
65Feb 12Steve StricklandFormal demob: "0700-1700 to demobilize"DEVD-0151
66Feb 12Steve Strickland"Toya spoke to me about the second addendum"AEVD-0002
68Feb 13Steve Strickland"all looks good" / "things are looking pretty good"AEVD-0155
Key Takeaway: Every city official who interacted with JWTC either directed work, approved work, or received detailed reports about scale and raised zero objections. The full 68-authorization register is available in the companion markdown document.
4
Financial Summary

4.1 Contract Rate Schedule

Equipment TypeHourly RateSourceStatus
Skid Steer (w/ operator)$225/hrOriginal Contract✅ Executed
Wheeled Loader$325/hrOriginal Contract✅ Executed
Dump Truck (10-ton, w/ driver)$175/hrAmendment 1✅ Executed
Salt Truck$180/hrAmendment 2 (requested)⚠️ Never executed
Operations Supervisor$150/hrAmendment 2 (requested)⚠️ Never executed
Field Crew Supervisor$125/hrAmendment 2 (requested)⚠️ Never executed

4.2 Total Processed Payroll

LocationOperatorsHoursAmount
Neiman~1,924~20,444$5,967,988
M&T Stadium~977~11,644$5,237,366
TOTAL~32,088$11,205,354

4.3 Estimated Daily Billing to City

DateEquipment DeployedEst. Daily Billing
Feb 3134 skids, ~18 dumps~$838,200
Feb 4236 skids, 44 dumps, 3 loaders~$1,482,600
Feb 5-7Ramping to peak~$1.2M–$1.6M/day
Feb 9 (peak)295 skids, 81 dumps, 15 loaders, 10 salt~$2,093,400
Feb 10-11Sustained peak~$1.8M–$2.0M/day
Feb 12Demob (0700-1700)~$200K+
Sandra Calligan's Awareness: Sandra reportedly called Brian Benoit about $2.2M/day in spend — aligning with peak equipment counts. The city was aware of the daily burn rate and continued directing operations without scaling back.
5
Equipment Deployment Record

5.1 Equipment Count Trajectory — As Reported to City

DateSkid SteersDump TrucksLoadersSalt TrucksReported ToResponse
Feb 3134ToyaNo objection
Feb 4236442-3All officialsNo objection
Feb 9295811510ToyaNo objection

5.2 Variance Against Contract

EquipmentAuthorizedActual (Feb 9)Variance% Over
Skid Steers204295+91+44%
Dump Trucks5081+31+62%
Wheel Loaders415+11+275%
Salt Trucks010+10N/A
Supervisors012+12N/A
Critical: Toya Sykes personally requested these equipment counts on at least 5 separate occasions. She received the numbers, continued directing operations, and raised zero objections. This constitutes ratification under contract law.

5.3 Every Equipment Type Was City-Requested

EquipmentRequested ByQuoteEvidence
Dump TrucksToya Sykes"I need a dump truck"EVD-0030
Salt TrucksToya Sykes"2 salt trucks over at 1600 Northgate"EVD-0134
Wheeled LoaderToya Sykes"we need to bring a wheeled loader"EVD-0032
Lightning LoadersToya Sykes"We need lightning loaders"EVD-0067
DozerSteve Strickland"do we have any dozer in theater?"EVD-0143
6
Scope Evolution Timeline

The scope expanded dramatically. Every expansion was driven by the city — not JWTC.

6.1 How the City's Own Definition Drove Expansion

Original Contract: Skid steers to clear snow from alleys. Skid steers push snow → creates piles.
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 Logic Chain:
1. City defines scope as REMOVAL (not pushing) → requires dump trucks
2. City demands salting → requires salt trucks
3. Managing 9+ dump sites → requires loaders, eventually a dozer
4. Coordinating 295+ units, 450 workers → requires supervisors

Every equipment type JWTC deployed was a direct consequence of the city's own scope definition.

6.2 Political Pressure Trail

The scope wasn't just operationally driven — it was politically driven:

Feb 7: City Council Member Paris Gray → DPW Director Abu-Hakim → Division Manager Galloway → JWTC subs. Elected officials pressured DPW, who routed work to JWTC. (EVD-0084)
7
Amendment Analysis

7.1 Amendment 1 — The Email/PDF Mismatch

ElementSandra's Email (Feb 5)Signed PDF (Feb 7)
Equipment"50 skid steers""50 Dump Trucks"
RateNot stated$175.00/hr
Legal StatusCover emailBinding signed document
What this proves: The signed legal document controls. The mismatch demonstrates DPW was thinking about expanding both skid steers AND dump trucks — confirming the city knew equipment was scaling across all categories.

7.2 Amendment 2 — Acknowledged But Never Executed

DateEventEvidence
Feb 6Charlene formally requests Amendment 2Email
Feb 7Sandra: "We are reviewing... will process it soon"Email
Feb 12Steve: "Toya spoke to me about the second addendum"EVD-0002
Feb 12Operations conclude — Amendment 2 never executed
10 salt trucks and 12 supervisors operated for 6–9 days at the city's direction without formal amendment — because the city failed to execute their own paperwork. The city's administrative failure should not void JWTC's right to payment.

7.3 Equipment Operating Before Amendments

EquipmentFirst DeployedAmendment SignedGap
Dump TrucksFeb 3Feb 74 days
Salt TrucksFeb 4Never9+ days
SupervisorsFeb 1Never12+ days
8
Unanswered Questions Register NEW — 19 Questions

JWTC raised 19 specific questions to DPW officials. Most were never answered.

8.1 Critical Unanswered Items

#DateWho AskedQuestionDirected ToStatus
1Feb 12Patrick"Unit counts changed on the fly... Is that going to present an issue on billing?"SteveNO RESPONSE
2Feb 12Patrick"Please respond to my email this morning"SteveNO RESPONSE
5Feb 6CharleneAmendment 2 for salt trucks — addendum requestSandraNEVER EXECUTED
8Feb 5PatrickTowed truck resolution — $1,850SteveNO RESOLUTION
9Feb 9PatrickDozer/excavator clearance and pricingToyaNEVER RESOLVED
11Feb 12PatrickWritten confirmation demob is completeSteveNEVER PROVIDED
12Feb 12PatrickFinal timesheet reconciliation agreementSteveNEVER PROVIDED
13Feb 12PatrickInvoicing timeline through WorkdaySteveNEVER PROVIDED

8.2 Response Time Asymmetry

DirectionRequest TypeResponse Time
City → JWTCEquipment deploymentMinutes to hours
City → JWTCPress conference numbers"Not a minute late"
JWTC → CityBilling clarificationNEVER
JWTC → CityAmendment 2 execution7+ days → NEVER
JWTC → CityDemob sign-off itemsNEVER
JWTC's Position: The city's silence does not create a discount. Work was performed at city direction. Questions were asked in good faith. JWTC invoices based on actual work performed.
9
Contradiction Register NEW — 8 Contradictions
CONTR-001: Amendment 1 — Email Says "Skid Steers," Document Says "Dump Trucks"
Sandra's email: "50 skid steers." Signed PDF: "50 Dump Trucks @ $175/hr." The signed document controls — but the confusion confirms the city knew both equipment types were expanding. EVD-0001
CONTR-002: Salt Domes — "Open" vs. Actually Refusing Service
City said domes were open. JWTC was refused salt at least 3 times. Cost JWTC idle time and wasted fuel. EVD-0105, EVD-0115, EVD-0131
CONTR-003: Pimlico Dump Site — Open/Closed/Open/Closed/Open
Feb 11: City said open → crews turned away → city said open again → still turned away → finally open. Loaded dump trucks drove in circles. All idle time is billable. EVD-0145
CONTR-004: Scope = "REMOVAL" But Contract Only Covered Pushing
Original contract: skid steers (push snow). Toya's definition: "SNOW REMOVAL — creating piles is NOT the scope!" Her own definition requires dump trucks that weren't in the original contract. EVD-0135, EVD-0138
CONTR-005: Amendment 2 — "Will Process It Soon" → Never Executed
Sandra (Feb 7): "reviewing... will process soon." Steve (Feb 12): "getting that done today or tomorrow." Operations ended. Amendment never executed. EVD-0002
CONTR-006: City Received Equipment Counts — Never Corrected Them
Feb 4: 236 skids, 44 dumps. Feb 9: 295 skids, 81 dumps, 15 loaders, 10 salt. City took zero corrective action. Toya kept directing operations. EVD-0038, EVD-0058
CONTR-007: "Reset Day" Discussed — Never Happened
Steve (Feb 6): "Maybe we need a reset day." Operations continued at peak intensity through Feb 12. EVD-0004
CONTR-008: Day 1 Failure → 11 More Days of Reliance
Only 6/50 skids on Day 1. City could have terminated. Instead: expanded scope, added amendments, praised JWTC as "ROCKSTARS." Waiver through continued acceptance.
10
Safety & Working Conditions

JWTC crews operated 24/7 in dangerous Baltimore neighborhoods during freezing winter conditions. Ten safety incidents were documented.

2 Critical Incidents
3 High Severity
5 Medium / Low-Med

10.1 Critical Incidents

Feb 4 — Worker Nico Somolec Assaulted: Bilateral jaw fractures, medically induced coma, intubated, surgery required. Assaulted near True Chesapeake restaurant. Sandra contacted 911. EVD-0114
Feb 9 — SHOTS FIRED at 301 E 28th St: A skid steer was struck by a bullet. Kubota windshield has bullet hole (photo documented). No injuries. Toya's response: "Have mercy... Please have the crews pack up and move on to the next location." EVD-0037

10.2 Additional Gun/Weapon Incidents

DateLocationIncidentEvidence
Feb 4W Lexington / N PoppletonGun incident — screenshot forwarded to ToyaEVD-0041
Feb 5UndisclosedGun pulled on crew — evacuated, cussed at on returnEVD-0063
Feb 9City streetsPolice prioritization failure — Patrick couldn't get police support
Relevance to Invoice: These conditions justify premium emergency rates, explain operational delays from evacuated work zones, and document that JWTC's workforce risked their lives executing city directives.
11
Responsibility Matrix (RACI)
ActivityCity (DPW)JWTCWhat This Means
What equipment to deployA / RICity told JWTC what to send
How many unitsA / RIChanged "on the fly" by DPW
Where to stageA / RI5 staging sites — all city-directed
Where to dump snowA / RI9+ dump sites — all city-managed
Which routes to clearA / RISpecific addresses and deadlines
Scope definitionA / RI"SNOW REMOVAL" — city's words
Operating scheduleA / RI24-hour ops; demob timing
Amendment executionA / RCDPW drafted; JWTC requested
Executing field workIRJWTC performed the work
Tracking hoursIRJWTC + City QR system
Raising billing concernsRJWTC flagged; city didn't respond
The pattern across every row: The City of Baltimore DPW made the decisions. JWTC carried them out. The city was satisfied with the work. Now it is time to pay.
12
Evidence Index — 87+ Items

12.1 Top 10 Evidence Items

RankRefDateDescription
1EVD-0038Feb 9Toya receives 295/81/15/10 counts — no objection
2EVD-0135Feb 8Toya: "This is a SNOW REMOVAL OPERATION"
3EVD-0138Feb 9Toya: "REMOVING the snow... salting as well"
4EVD-0010Feb 12Patrick raises billing concern — city never responds
5EVD-0116Feb 4Toya: "they are DPW CONTRACTORS"
6EVD-0151Feb 12Steve: formal demob directive
7EVD-0002Feb 12Steve confirms Amendment 2 was city's responsibility
8EVD-0058Feb 4236/44 reported — no objection from any official
9EVD-0155Feb 13Steve: "all looks good"
10EVD-0140Feb 9Toya allocates: "14 dumps 4 bobcats for your team"

12.2 City Satisfaction Statements

DateOfficialQuote
Feb 4Toya"I love this!!!!" (Snow Flow Dashboard)
Feb 4Toya"Thank you and your guys. I truly appreciate the help. I am grateful."
Feb 5Steve"Nice work. You guys keep safe and warm."
Feb 6Sandra"You guys are gettin' it done!"
Feb 8Toya"You guys are ROCKSTARS!!!"
Feb 13Steve"all looks good" / "things are looking pretty good"

12.3 Source Threads

ThreadParticipantsDatesKey Value
T1/T2Patrick ↔ SteveFeb 5-12Amendment 2 confirmed; billing discrepancy
T3Patrick ↔ ToyaFeb 3-9Equipment counts, shooting, city directives
T47-person groupFeb 4-8Main ops group; M&T staging; towed truck
T5Patrick → KendallFeb 7DPW Director engagement
T6Galloway + subsFeb 5-7City Council directives; dump truck requests
T7Patrick, Sandra, ToyaFeb 5Contract/reconciliation requests
T86-person groupFeb 3-4Earliest thread — QR system, salt, assault
T108-person groupFeb 6-13Demob, scope definition, dozer, dump sites
13
Vulnerability Assessment & Rebuttals NEW

This section anticipates 10 arguments the city could make — and documents JWTC's defense for each.

VULN-001: Day 1 Deployment Failure
City's argument: "JWTC breached the contract — only 6 of 50 skid steers showed up."
  • City continued working with JWTC for 11 more days — waiver
  • By Feb 3: 134 skids. By Feb 4: 236 skids — JWTC over-delivered
  • No termination notice; instead city expanded scope with amendments
  • Toya: "You guys are ROCKSTARS!!!"
VULN-002: Equipment Operating Before Amendment 1
City's argument: "Dump trucks operated Feb 3–7 before Amendment 1 was signed."
  • Toya ordered dump trucks Feb 3 — city initiated the deployment
  • City directed dump trucks throughout: "I need a dump truck" (EVD-0030)
  • City cannot direct equipment then refuse to pay because their paperwork was late
  • Quantum meruit: work performed and accepted
VULN-003: Amendment 2 Never Executed
City's argument: "No signed amendment for salt trucks and supervisors."
  • Sandra acknowledged Amendment 2 Feb 7: "will process it soon"
  • Steve confirmed Feb 12: "getting that done today or tomorrow" (EVD-0002)
  • Toya directly requested salt trucks (EVD-0134) and defined scope to include salting (EVD-0138)
  • City cannot benefit from their own administrative delay
  • Promissory estoppel: JWTC relied on city's representations
VULN-004: Equipment Counts Exceeded Contract
City's argument: "295 skids vs. 204 contracted — unauthorized overage."
  • Counts reported to Toya 5 separate times — zero objections (EVD-0038)
  • Toya requested counts and kept directing operations
  • Toya allocated equipment herself: "14 dumps 4 bobcats for your team" (EVD-0140)
  • Patrick raised discrepancy Feb 12 — city never responded (EVD-0010)
  • Tacit approval through continued direction = ratification
VULN-005: 72 Night Shift Dump Trucks
City's argument: "72 dump trucks on one night shift was excessive."
  • Toya allocated dumps to teams on Feb 9 (EVD-0140)
  • 81 total dumps reported — Toya didn't object (EVD-0038)
  • City's "REMOVAL" scope definition made high dump deployment necessary
  • 340 dump loads tracked by city on Feb 11 without complaint (EVD-0146)
VULN-006: City Knew Cost Was High ($2.2M/day)
City's argument: "We were alarmed by costs."
  • Sandra called Brian about spend — but city continued directing at same intensity
  • Awareness without corrective action = acceptance
  • At no point did any city official say "reduce" or "scale back"
VULN-007: JWTC Not Registered in Maryland
City's argument: "Contract invalid — JWTC not registered in MD."
  • DPW's legal team approved the contract knowing JWTC was TX-registered
  • City approved same-day despite this — waiver
  • Emergency operations doctrine
  • City cannot accept 12 days of service and then deny payment on a technicality
VULN-008: Payroll Phantom Names
City's argument: "JWTC payroll has fake names — billing is inflated."
  • Identified through JWTC's own quality review (triple-OCR) — transparency
  • City is billed on deployed equipment hours, not individual names
  • City's QR check-in data provides independent verification
VULN-009: No Daily Reconciliation
City's argument: "Hours aren't verified without daily sign-off."
  • Brian demanded reconciliation Feb 8 — city never implemented their side
  • Both parties have independent tracking systems
  • City's failure to participate doesn't void JWTC's right to payment
VULN-010: Scope Creep — JWTC Inflated Billing?
City's argument: "JWTC added equipment to boost revenue."
  • Every equipment type was city-requested (dump trucks, salt, loaders, dozer)
  • Every staging location was city-directed (5 sites)
  • Every dump site was city-managed (9+ sites)
  • City set the 24-hour schedule
  • Zero evidence of unilateral equipment addition by JWTC
14
Case Narrative NEW

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.

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 January 31 – February 12, 2026.

JWTC LLC

Brian Benoit
Owner / Principal, JWTC LLC

Date: _______________

Patrick Haygood
Project Manager, JWTC LLC

Date: _______________