Good morning, Ms. Sharma. Could you please state your full name for the record?

Priya Sharma.

And what is your position at NovaStream Logistics?

I'm the CEO and founder.

When did you found NovaStream?

I incorporated the company in August 2024. We started operations in October 2024.

Before founding NovaStream, what was your professional background?

I worked at Amazon for about six years, most recently as a logistics manager in their last-mile delivery division.

So you have experience with delivery operations?

Yes, extensive experience.

And at Amazon, were delivery drivers classified as employees or independent contractors?

MS. DOMINGUEZ-PARK: Objection. Relevance. Amazon's classification practices are not at issue here.

MR. McALLISTER: It goes to the witness's knowledge of classification issues.

MS. DOMINGUEZ-PARK: You may answer.

Amazon uses a variety of models. Some drivers are employees of Amazon, some work for Delivery Service Partners which are separate companies, and Amazon Flex drivers are independent contractors.

Were you involved in decisions about how Amazon classified workers?

Not directly. I was on the operations side.

But you were aware of the different classification models?

Generally, yes.

When you founded NovaStream, did you consider whether to classify drivers as employees or independent contractors?

Yes, we considered it.

And what factors went into that decision?

MS. DOMINGUEZ-PARK: Objection. To the extent this calls for communications with counsel, instruct the witness not to reveal privileged information.

I can answer generally. We looked at how other companies in the space operated. Most app-based delivery platforms use independent contractors. We also consulted with our lawyers about the legal requirements.

What did your lawyers tell you?

MS. DOMINGUEZ-PARK: Objection. Attorney-client privilege. Do not answer.

I'm not asking for the content of legal advice. I'm asking whether you received legal advice about classification.

Yes, we did.

And despite receiving legal advice, you chose to classify drivers as independent contractors?

Yes, based on our business model and the nature of the relationship with drivers.

Let's talk about that relationship. How many drivers does NovaStream currently have?

We have approximately 180 active drivers on the platform.

And how do drivers come to work for NovaStream?

They sign up through our app, complete a background check, go through onboarding, and then they can start accepting delivery blocks.

What is the onboarding process?

They complete our Delivery Excellence module, which is an online training that covers how to use the app, best practices for deliveries, customer service expectations, that sort of thing.

How long does that training take?

About 90 minutes to two hours.

Is it mandatory?

Yes, they have to complete it before they can access blocks.

Do drivers get paid for completing the training?

No, it's part of the onboarding process.

Ms. Sharma, you said drivers are independent contractors. What does that mean to you?

It means they're running their own businesses. They decide when to work, they can work for other companies, they provide their own vehicles. We're just providing a platform that connects them with delivery opportunities.

Let me ask you about some specific aspects of the relationship. You mentioned drivers decide when to work. How does that work?

Drivers log into the app and see available delivery blocks. They can choose to accept any block they want, or they can choose not to work at all on any given day.

Are there any consequences if a driver doesn't accept blocks?

No, they're free to work as much or as little as they want.

What about if a driver accepts a block and then cancels it?

If they cancel before checking in, there's no consequence. If they cancel after checking in, it can affect their priority for future blocks.

What do you mean by "priority"?

Drivers with higher reliability scores get earlier access to see and accept blocks. If someone cancels a lot after committing, their priority goes down.

So there are consequences for cancellations?

Only if they cancel after checking in. It's about reliability.

Let's talk about RouteGenius. What is that?

It's our route optimization algorithm. It suggests the most efficient delivery sequence based on traffic, time windows, location clustering.

Are drivers required to follow RouteGenius routes?

No, absolutely not. It's a suggestion. Drivers can take whatever route they want.

Are there any consequences if a driver doesn't follow the RouteGenius route?

No.

None at all?

The route is a suggestion. If a driver knows a better way, they're free to take it.

Ms. Sharma, I'm going to show you what's been marked as Plaintiff's Exhibit 12. Do you recognize this document?

(Examining document.) It looks like a Slack conversation.

Is this a conversation between you and Marcus Chen on August 14, 2025?

It appears to be.

I'd like to direct your attention to the message you sent at 3:30 PM. Could you read that for the record?

MS. DOMINGUEZ-PARK: Counsel, could you identify the specific message?

MR. McALLISTER: The message beginning "I know. Just be careful..."

(Reading.) "I know. Just be careful what you put in writing. The contract says they have autonomy so we should act like they do even if practically speaking there are consequences for not following the system."

Ms. Sharma, you just testified that there are no consequences for drivers who don't follow RouteGenius routes. But in this message, you say there are "consequences for not following the system." Which is true?

I think I was speaking generally about the system as a whole, not specifically about routes.

What consequences were you referring to?

I... I would need to see more context.

Let me be more direct. Were you instructing Mr. Chen to create the appearance of driver autonomy while actually maintaining control over how drivers do their work?

MS. DOMINGUEZ-PARK: Objection. Argumentative.

No, that's not what I meant. I was just reminding Marcus that we should be consistent in our communications.

Consistent with reality, or consistent with the contract?

Both. The contract reflects how the relationship actually works.

But your message suggests they're different. You say the contract gives autonomy but "practically speaking there are consequences." How is that consistent?

I misspoke in that message. Or it was taken out of context.

What context would change the meaning?

I don't remember exactly what we were discussing.

Let's move on. You said earlier that drivers can work for competing companies. Is that right?

Yes, absolutely. Many of our drivers also drive for DoorDash, Instacart, other platforms.

Can they work for competitors while they're doing a NovaStream block?

Well, no. During an active block, they should be focused on NovaStream deliveries.

So there IS a restriction on working for competitors?

Only during the block itself. From check-in to completion. Outside of that, they're free to do whatever they want.

The Independent Contractor Agreement at Section 3.5 prohibits drivers from performing work for competing platforms during active blocks. You're aware of that provision?

Yes.

And you believe that's consistent with independent contractor status?

Yes, because it only applies during the block when they've committed to do our deliveries.

Let me ask about substitutes. Can drivers have someone else do deliveries for them?

Yes, the contract allows that.

Has any driver ever actually used a substitute?

I believe we've had a couple of approved substitutions.

How many substitution requests have you received?

I don't know the exact number.

Do you know if Mr. Washington ever requested a substitute?

I believe he did, yes.

What happened with his request?

I... I'm not sure. I'd have to check with Marcus.

I'm showing you Plaintiff's Exhibit 15. This is a Slack exchange between Mr. Washington and Marcus Chen on July 17 through 21, 2025. Do you see where Mr. Washington requested a substitute because his mother was having surgery?

Yes, I see that.

And do you see Mr. Chen's response on July 21 that "we just don't have a good process for subs right now"?

Yes.

So the substitution right in the contract - drivers can't actually exercise it because NovaStream doesn't have a process?

We're working on improving that process.

But as of July 2025, ten months after you launched, you still didn't have a process for substitutes?

We were still building out our systems. It takes time.

Ms. Sharma, you testified earlier that NovaStream is "just providing a platform." But you have mandatory training, performance metrics, route suggestions with consequences, restrictions on competing work, and a substitution right that drivers can't actually use. Is NovaStream really just a platform?

MS. DOMINGUEZ-PARK: Objection. Argumentative. Compound.

We provide a platform. The training is informational. The metrics are for quality. The route suggestions are optional. The substitution process is being improved. We're a technology company that connects retailers with delivery capacity.

Let's talk about Mr. Washington specifically. Do you know who he is?

Yes, he was one of our drivers. He was injured in an accident.

What do you know about his performance?

He was one of our best drivers. High ratings, very reliable.

Do you know his rating?

I think it was 4.97 or something like that. Very high.

And how many deliveries did he complete?

I don't remember exactly. A few thousand, I think.

What happened on September 15, 2025?

He was in a car accident while doing deliveries. Another driver ran a red light and hit him.

What did NovaStream do after the accident?

We sent someone to pick up the packages. We reached out to make sure he was okay.

Did NovaStream take any responsibility for his medical expenses?

No, because he's an independent contractor. He's responsible for his own insurance.

Did NovaStream have workers' compensation insurance that would have covered him if he were an employee?

I assume so. We have workers' comp for our actual employees.

But not for drivers?

No, because they're independent contractors.

I want to ask about a deduction from Mr. Washington's final payment. Are you aware that NovaStream deducted $225.25 for damaged packages?

I'm not familiar with the details of that.

You're the CEO and you don't know about a $225 deduction from a driver who was just in a car accident?

Finance handles payroll. I don't review individual driver payments.

Let me show you Plaintiff's Exhibit 18. This is a Slack conversation between Marcus Chen and Diane Okonkwo on September 22, 2025. Mr. Chen asks about the $225 deduction and says, "This seems really unfair. The guy is in the hospital and we're charging him for something that wasn't his fault." Were you aware of this concern?

I was not directly involved in that conversation.

But you're the CEO. Decisions about charging an injured driver for damaged packages wouldn't come to your attention?

Day-to-day payroll decisions are handled by the finance team.

Do you agree with Mr. Chen that charging Mr. Washington for packages damaged in an accident that wasn't his fault is "really unfair"?

MS. DOMINGUEZ-PARK: Objection. Calls for speculation and legal conclusion.

I think the system applied the standard formula. If there was an error, we can look at it.

What is the "standard formula"?

If packages are damaged while in a driver's custody, the driver is responsible for the value.

Even if the damage wasn't the driver's fault?

That's how the system works. The driver has custody of the packages.

Ms. Sharma, how many drivers has NovaStream deactivated since launching?

I don't know the exact number. Not many. Maybe around twelve or fifteen.

For what reasons?

Usually low ratings, reliability issues, sometimes conduct issues.

You mentioned earlier that one of your best drivers was a woman who believed she was rated unfairly because of race. Do you recall that situation?

MS. DOMINGUEZ-PARK: Objection. Assumes facts not in evidence. The witness has not mentioned any such situation.

MR. McALLISTER: Let me rephrase. Ms. Sharma, has NovaStream ever deactivated a driver who complained that customer ratings were racially biased?

I... I'm not sure I'm comfortable answering that. There may be privacy issues.

MS. DOMINGUEZ-PARK: You can answer generally without identifying the individual.

I believe there was a situation where a driver raised concerns about ratings. I don't remember all the details.

Was she deactivated despite raising those concerns?

I would have to check the records.

One final area, Ms. Sharma. You testified that NovaStream is a technology company. How much of NovaStream's revenue comes from delivery services versus technology licensing or other sources?

Essentially all of our revenue comes from delivery services at this point.

So NovaStream's entire business is delivery?

Our technology enables delivery. But yes, the revenue comes from delivery fees.

And your drivers perform those deliveries?

Yes.

So without drivers performing deliveries, NovaStream would have no revenue?

That's true of any platform business.

Thank you, Ms. Sharma. I have no further questions at this time.

Ms. Sharma, Mr. McAllister asked you about the August 14 Slack message. When you wrote "consequences for not following the system," what system were you referring to?

I was speaking generally about our platform. There are natural consequences in any business. If you provide good service, you get good ratings. If you're reliable, you get more opportunities. That's not us imposing control - that's how any service business works.

When you said "act like they do" have autonomy, what did you mean?

I meant we should be consistent in our communications. Drivers DO have autonomy. The contract reflects that. I was reminding Marcus to communicate clearly.

Did you instruct Marcus to deceive anyone?

No, absolutely not.

Did you instruct him to say things that weren't true?

No.

Moving to the substitution process - you testified that NovaStream is improving that process. Is that true?

Yes, we're implementing a more formalized system for handling substitution requests.

Regarding the deduction from Mr. Washington's final payment - is that deduction something you personally authorized?

No, it was applied automatically by our payment system based on standard policies.

And those policies are disclosed to drivers in the Independent Contractor Agreement?

Yes.

Thank you. No further questions.

Ms. Sharma, you said the deduction policies are disclosed in the Independent Contractor Agreement. Can you point me to the specific provision that authorizes deducting $225 for packages damaged in an accident that wasn't the driver's fault?

I don't have the agreement in front of me.

You're the CEO and you don't know whether your own agreement authorizes this deduction?

MS. DOMINGUEZ-PARK: Objection. Asked and answered. Argumentative.

I trust that our legal and finance teams ensure our policies are proper.

No further questions.