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 propounds the following Interrogatories to Defendant NovaStream Logistics, LLC, pursuant to R. 4:17-1. Defendant shall answer these Interrogatories under oath within the time prescribed by the New Jersey Court Rules.

Definitions

For purposes of these Interrogatories:

1. "You," "Your," "Defendant," and "NovaStream" refer to NovaStream Logistics, LLC, its officers, directors, employees, agents, representatives, attorneys, and any other persons acting on its behalf.
2. "Plaintiff" and "Washington" refer to Jamal T. Washington.
3. "Document" has the meaning set forth in R. 4:18-1 and includes all writings, recordings, electronically stored information, and other tangible things.
4. "Communication" means any oral or written exchange of information, including emails, text messages, Slack messages, letters, memoranda, and conversations.
5. "Driver" refers to any individual who performed delivery services through NovaStream's platform, regardless of classification.
6. "The Agreement" refers to the Independent Contractor Agreement between NovaStream and Plaintiff.
7. "The Accident" refers to the motor vehicle collision involving Plaintiff on September 15, 2025.
8. "RouteGenius" refers to NovaStream's route optimization algorithm and related software.
9. "The App" refers to the NovaStream Driver App mobile application.
10. "Identify" when used with respect to a person means to state the person's full name, current or last known address, telephone number, and relationship to NovaStream.
11. "Identify" when used with respect to a document means to state the document's title, date, author, recipient(s), and current location or custodian.

Interrogatories

Corporate Information

Interrogatory No. 1:

Identify all officers, directors, and managers of NovaStream from January 2024 to present, including their titles, dates of service, and current contact information.

Interrogatory No. 2:

Describe NovaStream's corporate structure, including any parent companies, subsidiaries, or affiliated entities, and identify any individuals or entities holding an ownership interest of 10% or more.

Interrogatory No. 3:

State NovaStream's total annual revenue for calendar years 2024 and 2025, and identify what percentage of that revenue was derived from delivery services.

Driver Classification

Interrogatory No. 4:

Describe in detail the criteria NovaStream uses to determine whether an individual providing delivery services is classified as an "independent contractor" versus an "employee."

Interrogatory No. 5:

Identify all individuals at NovaStream who were involved in developing, reviewing, or approving the Independent Contractor Agreement used with drivers, including the version signed by Plaintiff.

Interrogatory No. 6:

State whether NovaStream sought legal advice regarding driver classification prior to launching its platform, and if so, identify the attorney(s) or law firm(s) consulted and the dates of such consultations. (NovaStream may assert privilege in response to this interrogatory but must provide a privilege log.)

Interrogatory No. 7:

Identify any government agency (federal, state, or local) that has audited, investigated, or inquired about NovaStream's classification of drivers as independent contractors, including the agency name, date(s) of contact, and outcome of any audit or investigation.

Interrogatory No. 8:

State the total number of drivers who have provided delivery services through NovaStream's platform from January 2024 to present, and state how many were classified as independent contractors versus employees.

Control and Operations

Interrogatory No. 9:

Describe in detail the training that drivers are required to complete before providing delivery services through NovaStream's platform, including the content, duration, format (in-person, online, etc.), and whether completion is mandatory.

Interrogatory No. 10:

Describe in detail how RouteGenius operates, including: (a) what factors the algorithm considers in generating routes; (b) whether drivers are required, expected, or encouraged to follow RouteGenius routes; and (c) any consequences (including effects on ratings, block allocation, or compensation) for drivers who deviate from RouteGenius routes.

Interrogatory No. 11:

Describe all performance metrics NovaStream tracks for drivers, including but not limited to customer ratings, delivery completion rates, route efficiency, and block cancellation rates.

Interrogatory No. 12:

Describe the criteria and process by which NovaStream determines which drivers receive priority access to delivery Blocks, including any algorithmic or automated factors.

Interrogatory No. 13:

State whether NovaStream has any dress code, appearance standards, or conduct requirements for drivers, and if so, describe such requirements in detail and state any consequences for non-compliance.

Interrogatory No. 14:

Describe NovaStream's policy and process for drivers to designate substitutes to perform deliveries on their behalf, including: (a) how substitution requests are submitted; (b) who reviews such requests; (c) criteria for approval or denial; (d) the typical timeframe for responding to requests; and (e) how many substitution requests have been submitted, approved, and denied since January 2024.

Plaintiff-Specific

Interrogatory No. 15:

Describe all training Plaintiff was required to complete before providing delivery services for NovaStream, including dates and content.

Interrogatory No. 16:

State the total number of deliveries Plaintiff completed for NovaStream, the total compensation paid to Plaintiff, and all deductions made from Plaintiff's compensation, itemized by category and amount.

Interrogatory No. 17:

Identify all customer complaints or negative feedback received regarding Plaintiff, including the date, substance of each complaint, and any action taken by NovaStream in response.

Interrogatory No. 18:

Describe in detail Plaintiff's July 2025 request to designate a substitute driver, including: (a) the date the request was received; (b) who received the request; (c) what action, if any, was taken in response; (d) whether the request was approved, denied, or not responded to; and (e) the reason for any denial or non-response.

Interrogatory No. 19:

Describe any communications between NovaStream personnel and Plaintiff regarding RouteGenius routes, delivery methods, appearance standards, or other aspects of how Plaintiff performed his work.

The Accident

Interrogatory No. 20:

Describe all actions NovaStream took in response to the Accident, including any communications with Plaintiff, any investigation conducted, and any changes to policies or procedures implemented as a result.

Interrogatory No. 21:

State whether NovaStream maintained workers' compensation insurance that would have covered Plaintiff if he had been classified as an employee, and if so, identify the insurance carrier and policy number.

Interrogatory No. 22:

Describe the basis for the $225.25 deduction from Plaintiff's final payment labeled "package value recovery," including: (a) how the amount was calculated; (b) what policy or agreement provision authorized the deduction; and (c) whether similar deductions have been made for other drivers in accident situations.

Deductions and Compensation

Interrogatory No. 23:

Describe all categories of deductions NovaStream makes or has made from driver compensation, including: (a) the name or description of each deduction category; (b) the basis or formula for calculating each deduction; (c) the policy or agreement provision authorizing each deduction; and (d) whether driver consent is obtained before each deduction is made.

Interrogatory No. 24:

For each deduction made from Plaintiff's compensation, state: (a) the date; (b) the amount; (c) the category; (d) the specific reason for the deduction; and (e) whether Plaintiff was notified of the deduction in advance.

Interrogatory No. 25:

State whether NovaStream has ever reimbursed drivers for tolls, parking fees, or other expenses incurred while performing deliveries, and if so, describe the circumstances and amounts of any such reimbursements.

Instructions

1. These Interrogatories are continuing in nature. If you obtain additional information after serving your answers, you must promptly supplement your responses.
2. If you object to any Interrogatory, state the grounds for the objection with specificity. If you object to part of an Interrogatory, answer the remaining part.
3. If you claim privilege for any information, provide a privilege log identifying the nature of the information withheld and the basis for the privilege claim.
4. Your answers must be signed under oath by an officer or agent of NovaStream competent to testify to the matters stated.

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Dated: March 15, 2026