SUPERIOR COURT OF NEW JERSEY
LAW DIVISION — ESSEX COUNTY

JAMAL T. WASHINGTON,
Plaintiff,

v.

NOVASTREAM LOGISTICS, LLC,
Defendant.

Docket No.: ESX-L-001847-26

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Plaintiff Jamal T. Washington, by and through his attorneys, McAllister & Vega, LLP, hereby requests that Defendant NovaStream Logistics, LLC produce for inspection and copying the documents described below, pursuant to R. 4:18-1, at the offices of McAllister & Vega, LLP, 180 Broad Street, Suite 1200, Newark, NJ 07102, within thirty (30) days of service of this Request.

Definitions

The definitions set forth in Plaintiff's First Set of Interrogatories are incorporated herein by reference.

Additionally:

1. "Concerning" and "relating to" mean referring to, describing, evidencing, constituting, or being in any way logically or factually connected with the matter described.
2. "ESI" means electronically stored information, including emails, text messages, instant messages, Slack communications, database records, and any other digital files.

Instructions

1. Produce all documents in your possession, custody, or control, including documents held by agents, attorneys, accountants, or other representatives.
2. Produce documents as they are kept in the ordinary course of business, organized by category corresponding to the categories in this Request.
3. For ESI, produce in native format or searchable PDF, including all metadata.
4. If any document is withheld based on privilege, provide a privilege log containing: (a) the document date; (b) author; (c) recipient(s); (d) document type; (e) subject matter (without revealing privileged content); and (f) the specific privilege claimed.
5. If a document is no longer in your possession, state: (a) whether it ever existed; (b) when it was last in your possession; (c) why it is no longer available; and (d) the identity of any person who may possess the document.

Document Requests

Corporate Documents

Request No. 1:

All organizational documents for NovaStream, including articles of organization, operating agreements, bylaws, and any amendments thereto.

Request No. 2:

All documents concerning NovaStream's business model, including business plans, investor presentations, pitch decks, and marketing materials describing NovaStream's services.

Request No. 3:

All financial statements, tax returns, and audited or unaudited financial reports for NovaStream for calendar years 2024 and 2025.

Driver Agreements and Policies

Request No. 4:

All versions of the Independent Contractor Agreement used with drivers from January 2024 to present, including redlines showing changes between versions.

Request No. 5:

All policies, procedures, guidelines, handbooks, or manuals provided to drivers or used by NovaStream personnel in managing drivers.

Request No. 6:

All training materials provided to drivers, including the "Delivery Excellence" training program and any other orientation or instructional materials.

Request No. 7:

All documents concerning driver dress codes, appearance standards, or conduct requirements.

Request No. 8:

All documents concerning the driver substitution process, including policies, request forms, approval records, and communications about substitution requests.

RouteGenius and Technology

Request No. 9:

All documents describing the RouteGenius algorithm, including technical specifications, user guides, and any documents explaining how routes are generated or optimized.

Request No. 10:

All documents concerning how driver performance is measured, tracked, or evaluated, including descriptions of rating systems, efficiency metrics, and block allocation algorithms.

Request No. 11:

All documents concerning the consequences for drivers who deviate from RouteGenius-recommended routes, including any policies, system configurations, or communications addressing route deviation.

Request No. 12:

All documents concerning the NovaStream Driver App, including user interface designs, feature specifications, and documentation of app functionality.

Plaintiff-Specific Documents

Request No. 13:

Plaintiff's complete driver file, including all agreements signed, onboarding documents, training records, and any other documents in Plaintiff's personnel or contractor file.

Request No. 14:

All payment records, earnings statements, 1099 forms, and deduction documentation for Plaintiff from March 2025 through September 2025.

Request No. 15:

All records of deliveries completed by Plaintiff, including delivery logs, GPS data, timestamps, and delivery confirmation records.

Request No. 16:

All customer ratings, reviews, complaints, or feedback concerning Plaintiff.

Request No. 17:

All communications (emails, Slack messages, text messages, or other) to, from, or concerning Plaintiff.

Request No. 18:

All documents concerning Plaintiff's July 2025 request to designate a substitute driver.

Request No. 19:

All RouteGenius route recommendations generated for Plaintiff and any records of Plaintiff's route compliance or deviation.

Request No. 20:

All documents concerning any performance issues, warnings, or disciplinary actions involving Plaintiff.

The Accident

Request No. 21:

All documents concerning the September 15, 2025 accident involving Plaintiff, including incident reports, photographs, police reports, insurance claims, and internal communications.

Request No. 22:

All documents concerning the $225.25 "package value recovery" deduction from Plaintiff's final payment, including the calculation, authorization, and any communications about this deduction.

Request No. 23:

All documents concerning Plaintiff's workers' compensation claim, including NovaStream's response to the claim and any communications with insurers or the Division of Workers' Compensation.

Classification Documents

Request No. 24:

All communications (internal or external) concerning whether NovaStream's drivers should be classified as independent contractors or employees.

Request No. 25:

All legal opinions, memoranda, or advice received by NovaStream concerning driver classification. (NovaStream may assert privilege but must provide a privilege log.)

Request No. 26:

All documents concerning any government audit, investigation, or inquiry into NovaStream's classification of drivers.

Request No. 27:

All documents concerning any litigation, arbitration, administrative proceeding, or demand involving claims that NovaStream misclassified drivers.

Request No. 28:

All communications with other gig economy or delivery companies concerning driver classification practices.

Deactivation and Discipline

Request No. 29:

All documents concerning the criteria and process for deactivating drivers, including policies, thresholds, and appeal procedures.

Request No. 30:

Records of all drivers deactivated from January 2024 to present, including the date, reason, and any documentation of the deactivation decision. (Driver names may be redacted, but other information must be provided.)

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Dated: March 15, 2026