On January 16, 2014 a
Party Discovery
was filed
involving a dispute between
Planet T Uniforms, Inc.,
and
Discovery Schools Inc,
Florida Charter Foundation, Inc.,
Iuniforms Inc,
Rogers, Jon Thomas,
Shellow, Richard,
Sznitken, Scott,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 70540506 E-Filed 04/11/2018 10:26:13 AM
IN THE CIRCUIT COURT OF THE
17"! JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY FLORIDA
CASE NO.: CACE 14-001087 (04)
PLANET T UNIFORMS, INC.,
Plaintiff,
v.
FLORIDA CHARTER FOUNDATION, INC.
D/B/A FRANKLIN ACADEMY CHARTER
SCHOOL, DISCOVERY SCHOOLS, _ INC.,
iUNIFORMS, INC., RICHARD SHELLOW, JON
THOMAS ROGERS, AND SCOTT SZNITKEN,
Defendant.
/
PLAINTIFF’S RESPONSE TO DEFENDANT, iUNIFORMS, INC.’S
FIRST REQUEST FOR ADMISSIONS
Plaintiff, PLANET T UNIFORMS, INC., (“PLANET T”), by and through undersigned
counsel, hereby files its Response to Defendant’s, iUNIFORMS, INC.’s (“iUniforms”) First
Request for Admissions and alleges as follows:
1. Plaintiff objects to this request on the basis that it is ambiguous making it difficult for
Plaintiff to truthfully admit or deny the matter as phrased. While Plaintiff has
produced all documents in her possession, custody or control in discovery
constituting or containing trade secrets that were misappropriated by iUniforms, Inc.,
Plaintiff has not produced all information constituting or containing trade secrets to
the extent that some of the trade secrets misappropriated by iUniforms, Inc. were not
reduced to document form.
2. Plaintiff objects to this request on the basis that it is ambiguous making it difficult for
Plaintiff to truthfully admit or deny the matter as phrased. While Plaintiff has
Page | of 3
*4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 4/11/2018 10:26:12 AM.****produced all documents in her possession, custody or control in discovery
constituting or containing trade secrets that were misappropriated by iUniforms, Inc.,
Plaintiff has not produced all information constituting or containing trade secrets to
the extent that some of the trade secrets misappropriated by Richard Shellow were not
reduced to document form.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished e-
service through the Florida Courts E-Filing Portal to the Service List below on April 11, 2018.
Respectfully Submitted,
DI PIETRO PARTNERS, LLP
901 E. Las Olas Blvd., Suite 202
Fort Lauderdale, FL 33301
Primary: service@ddpalaw.com
Telephone: (954) 712-3070
Facsimile: (954) 337-3824
/s/_ Rodolfo Mayor
DAVID DI PIETRO, ESQ.
Florida Bar No.: 10370
david@ddpalaw.com
NICOLE MARTELL, ESQ.
Florida Bar No.: 100172
nicole@ddpalaw.com
RODOLFO MAYOR, ESQ.
Florida Bar No.: 111647
rudy@ddpalaw.com
SERVICE LIST
Christopher M. David, Esq.
FUERST ITTLEMAN DAVID & JOSEPH, PL
1001 Brickell Bay Drive, 32"4 Floor
Miami, Florida 33131
Emails: cdavid@fuerstlaw.com; tdavid@fuerstlaw.com;
And jconcepcion@fuerstlaw.com
John L. McManus, Esq.
GREENBERG TRAURIG, P.A.
Page 2 of 3401 East Las Olas Blvd., Suite 2000
Fort Lauderdale, FL 33301
Emails: brownc@gtlaw.com; FLService@gtlaw.com; memanusj@gtlaw.com;
yeargina@gtlaw.com and horkyk@gtlaw.com
Page 3 of 3
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Filing # 70540506 E-Filed 04/11/2018 10:26:13 AM IN THE CIRCUIT COURT OF THE 17"! JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY FLORIDA CASE NO.: CACE 14-001087 (04) PLANET T UNIFORMS, INC., Plaintiff, v. FLORIDA CHARTER FOUNDATION, INC. D/B/A FRANKLIN ACADEMY CHARTER SCHOOL, DISCOVERY SCHOOLS, _ INC., iUNIFORMS, INC., RICHARD SHELLOW, JON THOMAS ROGERS, AND SCOTT SZNITKEN, Defendant. / PLAINTIFF’S RESPONSE TO DEFENDANT, iUNIFORMS, INC.’S FIRST REQUEST FOR ADMISSIONS Plaintiff, PLANET T UNIFORMS, INC., (“PLANET T”), by and through undersigned counsel, hereby files its Response to Defendant’s, iUNIFORMS, INC.’s (“iUniforms”) First Request for Admissions and alleges as follows: 1. Plaintiff objects to this request on the basis that it is ambiguous making it difficult for Plaintiff to truthfully admit or deny the matter as phrased. While Plaintiff has produced all documents in her possession, custody or control in discovery constituting or containing trade secrets that were misappropriated by iUniforms, Inc., Plaintiff has not produced all information constituting or containing trade secrets to the extent that some of the trade secrets misappropriated by iUniforms, Inc. were not reduced to document form. 2. Plaintiff objects to this request on the basis that it is ambiguous making it difficult for Plaintiff to truthfully admit or deny the matter as phrased. While Plaintiff has Page | of 3 *4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 4/11/2018 10:26:12 AM.****produced all documents in her possession, custody or control in discovery constituting or containing trade secrets that were misappropriated by iUniforms, Inc., Plaintiff has not produced all information constituting or containing trade secrets to the extent that some of the trade secrets misappropriated by Richard Shellow were not reduced to document form. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished e- service through the Florida Courts E-Filing Portal to the Service List below on April 11, 2018. Respectfully Submitted, DI PIETRO PARTNERS, LLP 901 E. Las Olas Blvd., Suite 202 Fort Lauderdale, FL 33301 Primary: service@ddpalaw.com Telephone: (954) 712-3070 Facsimile: (954) 337-3824 /s/_ Rodolfo Mayor DAVID DI PIETRO, ESQ. Florida Bar No.: 10370 david@ddpalaw.com NICOLE MARTELL, ESQ. Florida Bar No.: 100172 nicole@ddpalaw.com RODOLFO MAYOR, ESQ. Florida Bar No.: 111647 rudy@ddpalaw.com SERVICE LIST Christopher M. David, Esq. FUERST ITTLEMAN DAVID & JOSEPH, PL 1001 Brickell Bay Drive, 32"4 Floor Miami, Florida 33131 Emails: cdavid@fuerstlaw.com; tdavid@fuerstlaw.com; And jconcepcion@fuerstlaw.com John L. McManus, Esq. GREENBERG TRAURIG, P.A. Page 2 of 3401 East Las Olas Blvd., Suite 2000 Fort Lauderdale, FL 33301 Emails: brownc@gtlaw.com; FLService@gtlaw.com; memanusj@gtlaw.com; yeargina@gtlaw.com and horkyk@gtlaw.com Page 3 of 3