Party Discovery: PLANET T UNIFORMS, INC. Plaintiff vs. FLORIDA CHARTER FOUNDATION, INC., et al Defendant

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                                Filing # 73266380 E-Filed 06/07/2018 06:06:36 PM

IN THE CIRCUIT COURT OF THE 17'4 JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO.: CACE-14-001087 (04)

PLANET T UNIFORMS, INC.,
Plaintiff,
vz.

FLORIDA CHARTER FOUNDATION, INC.

D/B/A FRANKLIN ACADEMY CHARTER

SCHOOL, DISCOVERY SCHOOLS, INC.,

iUNIFORMS, INC., RICHARD SHELLOW, JON

THOMAS ROGERS, AND SCOTT SZNITKEN,
Defendants.

/

FLORIDA CHARTER FOUNDATION, INC.,
D/B/A FRANKLIN ACADEMY CHARTER
SCHOOL,

Counter-Plaintiff,
v.

PLANET T UNIFORMS, INC.,
Counter-Defendant.

/

DEFENDANT/COUNTER-PLAINTIFF FLORIDA CHARTER
FOUNDATION, INC.’S FOURTH REQUEST FOR ADMISSIONS TO
PLAINTIFF/COUNTER-DEFENDANT PLANET T UNIFORMS, INC.

Defendant/Counter-Plaintiff Florida Charter Foundation, Inc. (d/b/a Franklin
Academy Charter School) (“FRANKLIN”), through its undersigned attorney, pursuant
to Rule 1.370, Fla.R.Civ.P., demands that Plaintiff/Counter-Defendant, Planet T

Uniforms, Inc. (“PLANET T”), answer this request for admissions within 30 days from

the date hereof:

FUERST ITTLEMAN DAVID & JOSEPH
1001 BRICKELL BAY DRIVE, SUITE 3112, MIAMI, FL 33131 + T: 305.350.5690 + F: 305.371.8989

*4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 6/7/2018 6:06:36 PM.****1. Admit that the Plaintiff did not have written policies related to the
protection of its trade secrets during the period January 1, 2010 through December 31,
2013.

2. Admit that the Plaintiff did not have written procedures related to the
protection of its trade secrets during the period January 1, 2010 through December 31,
2013.

ot Admit that any information sent to Defendant Florida Charter
Foundation, Inc. by any person or entity that was not accompanied by an adequate
notice of exemption became a public record upon receipt by Florida Charter
Foundation, Inc.

4. Admit that any information sent to Defendant Florida Charter
Foundation, Inc. by Plaintiff or its representatives that was not accompanied by an
adequate notice of exemption became a public record upon receipt by Florida Charter
Foundation, Inc.

Bt Admit that any trade secrets sent to Defendant Florida Charter
Foundation, Inc. by Plaintiff or its representatives that was not accompanied by an
adequate notice of exemption became a public record upon receipt by Florida Charter
Foundation, Inc.

Dated: June 7, 2018 Respectfully submitted,

FUERST ITTLEMAN DAVID & JOSEPH
Attormeys for FLORIDA CHARTER
FOUNDATION, INC. D/B/A FRANKLIN
ACADEMY CHARTER SCHOOL

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FUERST ITTLEMAN DAVID & JOSEPH
1001 BRICKELL BAY DRIVE, SUITE 3112, MIAMI, FL 33131 * T: 305.350.5690 * F: 305.371.8989 © \WwWALERSELAW.COM1001 Brickell Bay Drive, Suite 3112
Miami, Florida 33131

Telephone: 305-350-5690
Facsimile: 305-371-8989

Email: cdavid@ fuerstlaw.com
Secondary: icrstlaw.com

 

By: /s/ Christopher M. David
CHRISTOPHER M. DAVID

Florida Bar No. 985163

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on June 7, 2018, the foregoing was e-filed using Florida’s e-
Filing Portal, and was served on counsel of record via the E-Service list associated with this action,
and served via electronic mail to Plaintiff's counsel, Di Pietro Partners, LLP, David Di Pietro,
Esq. (david@ddpalaw.com; service@ddpalaw.com om); Lisandra Estevez,
Esq. (lisandra@iddpalaw.com); Nicole Martell, Esq. (nicole@ddpalaw.com); Rodolfo Mayor, Esq.
(rudy(@ddpalaw.com); and to Co-l Defendants? counsel, Greenberg Traurig, P.A., Kenneth A.
Horky, Esq, John L. McManus, Esq. (flservice(@ytlaw.com; — horky k@ytl aw.com;

brownc@etlaw.com; memanusj@egtlaw.com; yearginal

aralegal(@ddpalaw.c«

   

 

 

By:  4s/ Christopher M. David
CHRISTOPHER M. DAVID

Florida Bar No. 985163

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FUERST ITTLEMAN DAVID & JOSEPH
1001 BRICKELL BAY DRIVE, SUITE 3112, MIAMI, FL 33131 * T: 305.350.5690 * F: 305.371.8989 © \WwWALERSELAW.COM