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Filing # 79932950 E-Filed 10/26/2018 02:01:50 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
PLANET T UNIFORMS, INC.,
Case No.: CACE 14-001087
Plaintiff,
vs.
FLORIDA CHARTER FOUNDATION, INC,
et al.,
Defendants.
/
DEFENDANT iUNIFORMS, INC.’S SUPPLEMENTAL REQUEST FOR PRODUCTION
OF DOCUMENTS TO PLAINTIFF
COMES NOW Defendant iUNIFORMS, INC., by and through its undersigned attorney,
pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, and requests Plaintiff to produce
for inspection, copying or photographing, within thirty days, the documents requested herein
below.
Instructions
1. Unless otherwise specified, the documents requested are the responsive
documents in the possession, control or custody of the plaintiff that were prepared, written, sent,
dated, received, applicable or in effect at any time up to the date of plaintiff's compliance with
this demand.
2. Each requested document shall be produced in its entirety. If a document
responsive to any request cannot be produced in full, it shall be produced to the extent possible
with an explanation stating why production of the remainder is not possible.
3. Each page or sheet produced by plaintiff is to be marked with a consecutive
document control number.
4. All documents produced in response to these requests shall be produced in the
same order as they are kept or maintained in the ordinary course of business and, where multiple
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/26/2018 2:01:50 PM.****pages or documents are assembled, collated, grouped, or otherwise attached, shall not be
separated or disassembled.
5. With respect to any document responsive to this request that is withheld from
production based upon a claim of privilege, please provide the information required pursuant to
Florida’s Rules of Civil Procedure.
6. If, for reasons other than a claim of privilege, you refuse to produce any document
requested herein, state the grounds upon which the refusal is based with sufficient specificity to
permit a determination of the propriety of such refusal.
7. If there are no documents responsive to any paragraph or subparagraph set forth
in these requests, please provide a written response so stating.
DOCUMENTS
REQUEST NO. 1:
All documents identified in response to i{UNIFORMS, INC.’s Supplemental Interrogatories to
plaintiff dated 09-25-2018.
REQUEST NO. 2:
All documents used or referred to in responding to iUNIFORMS, INC.’s Supplemental
Interrogatories to plaintiff dated 09-25-2018.
REQUEST NO. 3:
All documents concerning any efforts to ensure or maintain the secrecy or confidentiality of the
trade secrets information plaintiff claims was misappropriated by defendants.
REQUEST NO. 4:
All documents concerning any rule, policy, practice or procedure relating to the confidentiality
or secrecy, or lack of confidentiality or secrecy, of the trade secrets information plaintiff claims
was misappropriated by defendants.
REQUEST NO. 5:
All documents concerning any breach of any rule, policy, practice or procedure, relating to the
confidentiality or secrecy, or lack of confidentiality or secrecy, of the trade secrets information
plaintiff claims was misappropriated by defendants.
REQUEST NO. 6:
All documents concerning the value, if any, of the trade secrets information plaintiff claims was
misappropriated by defendants.REQUEST NO. 7:
All documents concerning the resumes or curricula vitae of any person on whom plaintiff intends
to rely as an expert witness in this action.
REQUEST NO. 8:
Documents sufficient to show plaintiffs organizational or personnel structure, including but not
limited to organization charts, flow charts and personnel directories.
REQUEST NO. 9:
All documents concerning the nature, calculation, and basis of any damages and injuries plaintiff
claims in this matter.
REQUEST NO. 10:
All documents evidencing or identifying the specific trade secrets owned by the Plaintiff that
were allegedly obtained by iUNIFORMS, INC.
REQUEST NO. 11:
All documents evidencing or identifying the manner by which iUNIFORMS, INC. is alleged to
have obtained any trade secrets owned by the Plaintiff.
REQUEST NO. 12:
All documents concerning any efforts to ensure or maintain the secrecy or confidentiality of the
trade secrets information plaintiff claims was misappropriated by UNIFORMS, INC. or anyone
acting on its behalf.
Certificate of Service
I HEREBY CERTIFY that a copy of the foregoing was served on this 26th day of
October, 2018 to: All counsels / parties of record by electronic mailing via the E-Filing Portal.
Robert P telly, Esq.
Robert P. Kelly, Esq.
FL Bar No.: 162930
Law Office of Robert P. Kelly
Counsels for iUniforms, Inc.
2514 Hollywood Boulevard,
Suite 307
Hollywood, Florida 33020
(954) 454-5555
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Filing # 79932950 E-Filed 10/26/2018 02:01:50 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA PLANET T UNIFORMS, INC., Case No.: CACE 14-001087 Plaintiff, vs. FLORIDA CHARTER FOUNDATION, INC, et al., Defendants. / DEFENDANT iUNIFORMS, INC.’S SUPPLEMENTAL REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF COMES NOW Defendant iUNIFORMS, INC., by and through its undersigned attorney, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, and requests Plaintiff to produce for inspection, copying or photographing, within thirty days, the documents requested herein below. Instructions 1. Unless otherwise specified, the documents requested are the responsive documents in the possession, control or custody of the plaintiff that were prepared, written, sent, dated, received, applicable or in effect at any time up to the date of plaintiff's compliance with this demand. 2. Each requested document shall be produced in its entirety. If a document responsive to any request cannot be produced in full, it shall be produced to the extent possible with an explanation stating why production of the remainder is not possible. 3. Each page or sheet produced by plaintiff is to be marked with a consecutive document control number. 4. All documents produced in response to these requests shall be produced in the same order as they are kept or maintained in the ordinary course of business and, where multiple *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/26/2018 2:01:50 PM.****pages or documents are assembled, collated, grouped, or otherwise attached, shall not be separated or disassembled. 5. With respect to any document responsive to this request that is withheld from production based upon a claim of privilege, please provide the information required pursuant to Florida’s Rules of Civil Procedure. 6. If, for reasons other than a claim of privilege, you refuse to produce any document requested herein, state the grounds upon which the refusal is based with sufficient specificity to permit a determination of the propriety of such refusal. 7. If there are no documents responsive to any paragraph or subparagraph set forth in these requests, please provide a written response so stating. DOCUMENTS REQUEST NO. 1: All documents identified in response to i{UNIFORMS, INC.’s Supplemental Interrogatories to plaintiff dated 09-25-2018. REQUEST NO. 2: All documents used or referred to in responding to iUNIFORMS, INC.’s Supplemental Interrogatories to plaintiff dated 09-25-2018. REQUEST NO. 3: All documents concerning any efforts to ensure or maintain the secrecy or confidentiality of the trade secrets information plaintiff claims was misappropriated by defendants. REQUEST NO. 4: All documents concerning any rule, policy, practice or procedure relating to the confidentiality or secrecy, or lack of confidentiality or secrecy, of the trade secrets information plaintiff claims was misappropriated by defendants. REQUEST NO. 5: All documents concerning any breach of any rule, policy, practice or procedure, relating to the confidentiality or secrecy, or lack of confidentiality or secrecy, of the trade secrets information plaintiff claims was misappropriated by defendants. REQUEST NO. 6: All documents concerning the value, if any, of the trade secrets information plaintiff claims was misappropriated by defendants.REQUEST NO. 7: All documents concerning the resumes or curricula vitae of any person on whom plaintiff intends to rely as an expert witness in this action. REQUEST NO. 8: Documents sufficient to show plaintiffs organizational or personnel structure, including but not limited to organization charts, flow charts and personnel directories. REQUEST NO. 9: All documents concerning the nature, calculation, and basis of any damages and injuries plaintiff claims in this matter. REQUEST NO. 10: All documents evidencing or identifying the specific trade secrets owned by the Plaintiff that were allegedly obtained by iUNIFORMS, INC. REQUEST NO. 11: All documents evidencing or identifying the manner by which iUNIFORMS, INC. is alleged to have obtained any trade secrets owned by the Plaintiff. REQUEST NO. 12: All documents concerning any efforts to ensure or maintain the secrecy or confidentiality of the trade secrets information plaintiff claims was misappropriated by UNIFORMS, INC. or anyone acting on its behalf. Certificate of Service I HEREBY CERTIFY that a copy of the foregoing was served on this 26th day of October, 2018 to: All counsels / parties of record by electronic mailing via the E-Filing Portal. Robert P telly, Esq. Robert P. Kelly, Esq. FL Bar No.: 162930 Law Office of Robert P. Kelly Counsels for iUniforms, Inc. 2514 Hollywood Boulevard, Suite 307 Hollywood, Florida 33020 (954) 454-5555