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Filing # 69270393 E-Filed 03/14/2018 03:33:02 PM
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.
TT I I II SI |
PLANET T UNIFORMS, INC.’S SECOND REQUEST FOR ADMISSIONS
TO DEFENDANT SCOTT SZNITKEN
COMES NOW Plaintiff, PLANET T UNIFORMS, INC., (“PLANET T”), by and
through undersigned counsel, hereby propounds its Second Request for Admissions on
Defendant, SCOTT SZNITKEN and requests that Defendant answer fully under oath in
accordance with Florida Rules of Civil Procedure 1.370.
1. Admit that Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter
School is considered a public school that takes part in the State of Florida’s
program of public education in accordance with Fla. Stat. 1002.33(1).
RESPONSE:
2. Admit that “Agency” as defined in Fla. Stat. 112.312(2) includes Florida Charter
Foundation, Inc. d/b/a Franklin Academy Charter School since it is treated as a
public school under Florida law.
RESPONSE:
Page 1 of 4
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/14/2018 3:33:01 PM.****Admit that you were an employee of an “Agency” as agency is defined in Fla.
Stat. 112.312(2) at any point from December 1, 2012 through June 19, 2015.
RESPONSE:
Admit that you directly or indirectly purchased, rented, or leased any goods or
services for Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter
School from a business entity in which you are an officer, partner, director, or
proprietor or in which you have material interest.
RESPONSE:
Admit that you disclosed or used information not available to members of the
general public for your personal gain or benefit or the personal gain or benefit of
any other person or business entity including but not limited to Uniforms, Inc.
RESPONSE:
Admit that you used or attempted to use your official position with Florida
Charter Foundation, Inc. d/b/a Franklin Academy Charter School to secure a
special privilege or benefit of any kind.
RESPONSE:
Admit that you used or attempted to use any property or resource within your trust
to secure a special privilege or benefit of any kind.
RESPONSE:
Admit that you used or attempted to use the performance of your official duties
with Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter School to
secure a special privilege or benefit of any kind.
RESPONSE:
Page 2 of 48. Admit that you violated Fla. Stat. 112.312(7) prohibiting employees of Florida
Charter Foundation, Inc. d/b/a Franklin Academy Charter School from having or
holding any employment or contractual relationship that will create a continuing
or frequently recurring conflict between your private interests and the
performance of your public duties.
RESPONSE:
9. Admit that you solicited or accepted anything of value, including a gift, loan,
reward, favor or service, based upon any understanding that your vote, official
action, or judgment as an employee of Florida Charter Foundation, Inc. d/b/a
Franklin Academy Charter School would be influenced thereby.
RESPONSE:
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 March 14, 2018.
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
NICOLE MARTELL, ESQ.
Florida Bar No.: 100172
nicole@ddpalaw.com
LISANDRA ESTEVEZ, ESQ.
Florida Bar No.: 111475
lisandra@ddpalaw.com
RODOLFO MAYOR, ESQ.
Florida Bar No.: 111647
rudy@ddpalaw.com
Page 3 of 4SERVICE LIST
Christopher M. David, Esq.
FUERST ITTLEMAN DAVID & JOSEPH, PL.
1001 Brickell Bay Drive, 32" Floor
Miami, Florida 33131
Emails: cdavid@fuerstlaw.com; tdavid@fuerstlaw.com;
And jconcepcion@fuerstlaw.com
Kenneth A. Horky, Esq.
GREENBERG TRAURIG, P.A.
401 East Las Olas Blvd., Suite 2000
Fort Lauderdale, Florida 33301
Emails: horkyk@gtlaw.com;
flservice@gtlaw.com; muehlfeldem@gtlaw.com
rosengartenrich@gtlaw.com; rosr@gtlaw.com
Page 4 of 4
Preview
Filing # 69270393 E-Filed 03/14/2018 03:33:02 PM 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. TT I I II SI | PLANET T UNIFORMS, INC.’S SECOND REQUEST FOR ADMISSIONS TO DEFENDANT SCOTT SZNITKEN COMES NOW Plaintiff, PLANET T UNIFORMS, INC., (“PLANET T”), by and through undersigned counsel, hereby propounds its Second Request for Admissions on Defendant, SCOTT SZNITKEN and requests that Defendant answer fully under oath in accordance with Florida Rules of Civil Procedure 1.370. 1. Admit that Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter School is considered a public school that takes part in the State of Florida’s program of public education in accordance with Fla. Stat. 1002.33(1). RESPONSE: 2. Admit that “Agency” as defined in Fla. Stat. 112.312(2) includes Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter School since it is treated as a public school under Florida law. RESPONSE: Page 1 of 4 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/14/2018 3:33:01 PM.****Admit that you were an employee of an “Agency” as agency is defined in Fla. Stat. 112.312(2) at any point from December 1, 2012 through June 19, 2015. RESPONSE: Admit that you directly or indirectly purchased, rented, or leased any goods or services for Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter School from a business entity in which you are an officer, partner, director, or proprietor or in which you have material interest. RESPONSE: Admit that you disclosed or used information not available to members of the general public for your personal gain or benefit or the personal gain or benefit of any other person or business entity including but not limited to Uniforms, Inc. RESPONSE: Admit that you used or attempted to use your official position with Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter School to secure a special privilege or benefit of any kind. RESPONSE: Admit that you used or attempted to use any property or resource within your trust to secure a special privilege or benefit of any kind. RESPONSE: Admit that you used or attempted to use the performance of your official duties with Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter School to secure a special privilege or benefit of any kind. RESPONSE: Page 2 of 48. Admit that you violated Fla. Stat. 112.312(7) prohibiting employees of Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter School from having or holding any employment or contractual relationship that will create a continuing or frequently recurring conflict between your private interests and the performance of your public duties. RESPONSE: 9. Admit that you solicited or accepted anything of value, including a gift, loan, reward, favor or service, based upon any understanding that your vote, official action, or judgment as an employee of Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter School would be influenced thereby. RESPONSE: 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 March 14, 2018. 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 NICOLE MARTELL, ESQ. Florida Bar No.: 100172 nicole@ddpalaw.com LISANDRA ESTEVEZ, ESQ. Florida Bar No.: 111475 lisandra@ddpalaw.com RODOLFO MAYOR, ESQ. Florida Bar No.: 111647 rudy@ddpalaw.com Page 3 of 4SERVICE LIST Christopher M. David, Esq. FUERST ITTLEMAN DAVID & JOSEPH, PL. 1001 Brickell Bay Drive, 32" Floor Miami, Florida 33131 Emails: cdavid@fuerstlaw.com; tdavid@fuerstlaw.com; And jconcepcion@fuerstlaw.com Kenneth A. Horky, Esq. GREENBERG TRAURIG, P.A. 401 East Las Olas Blvd., Suite 2000 Fort Lauderdale, Florida 33301 Emails: horkyk@gtlaw.com; flservice@gtlaw.com; muehlfeldem@gtlaw.com rosengartenrich@gtlaw.com; rosr@gtlaw.com Page 4 of 4