Preview
Filing # 68795539 E-Filed 03/05/2018 02:38:09 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,
Vv.
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.
/
NOTICE OF INTENT TO SERVE SUBPOENA UNDER RULE 1.351
FOR DOCUMENTS WITHOUT DEPOSITION
THE STATE OF FLORIDA:
TO:
YOU ARE NOTIFIED that pursuant to Rule 1.351(b), Florida Rules of Civil Procedure,
after fifteen (15) days from the date of this Notice, and if no objection is received from any party,
the undersigned will issue or apply to the Clerk of Court for issuance of the attached subpoena,
who are not parties, directed to:
STRATEGIC DISTRIBUTION, LP
D/B/A CLASSROOM SCHOOL UNIFORMS
9800 DE SOTO AVE.
CHATSWORTH, CA 91311
FAX: 888-283-7271
EMAIL: INFO@CLASSROOMUNIFORMS.COM.
To produce the items list at the time and place specified in the Subpoena.
DATED March 5, 2018.
*4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/5/2018 2:38:09 PM.****CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished via Email
through the Florida Courts E-Filing Portal to the service list below on Monday March 5, 2018.
SERVICE LIST
Christopher M. David, Esq.
Respectfully Submitted,
DI PIETRO PARTNERS, LLP
901 E. Las Olas Blvd., Suite 202
Fort Lauderdale, FL 33301
Primary: service@ddpalaw.com
Secondary: _paralegal@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
LISANDRA ESTEVEZ, ESQ.
Florida Bar No.: 111475
lisandra@ddpalaw.com
RODOLFO MAYOR, ESQ.
Florida Bar No.: 111647
rudy@ddpalaw.com
FUERST ITTLEMAN DAVID & JOSEPH, PL
1001 Brickell Bay Drive, 32" Floor
Miami, Florida 33131
Emails: cdavid@fuerstlaw.com; tdavid@fuerstlaw.com;
and dmuller@fuerstlaw.com
Richard Rosengarten, Esq.
GREENBERG TRAURIG, P.A.
401 East Las Olas Blvd., Suite 2000
Fort Lauderdale, FL 33301
Emails: rosengartenrich@gtlaw.com; rosr@gtlaw.com;
and horkyk@gtlaw.comIN 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,
Defendants.
/
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
(documents may be mailed or e-mailed in lieu of appearance)
THE STATE OF FLORIDA:
TO: STRATEGIC DISTRIBUTION, LP
D.B.A. CLASSROOM SCHOOL UNIFORMS
9800 DE SOTO AVE.
CHATSWORTH, CA 91311
FAX: 888-283-7271
EMAIL: INFO@CLASSROOMUNIFORMS.COM
YOU ARE COMMANDED to appear at the offices of D1 PIETRO PARTNERS, LLP 901
EAST LAS OLAS BLVD., SUITE 202, TEL: 954-712-3070 within ten (10) days of receipt of this
subpoena and to have with you at that time and place the documents or objects described in
Schedule “A”. The documents may be mailed or e-mailed in lieu of appearance.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this subpoena by providing legible copies of
the items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of the copies upon the payment
in advance of the reasonable cost of preparation. You may mail or deliver the copies to the
attorney whose name appears on this subpoena and thereby eliminate your appearance at the time
and place specified above. You have the right to object to the production pursuant to this
subpoena at any time before production by giving written notice to the attorney whose nameappears on this subpoena. THIS WILL NOT BE A LIVE DEPOSITION. NO TESTIMONY
WILL BE TAKEN.
If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as
provided above; or (3) object to this subpoena, you may be in contempt of court. You are
subpoenaed to appear by the following attorney, and unless excused from this subpoena by this
attorney or the court, you shall respond to this subpoena as directed.
DATED on this __ day of , 2018.
ds/
RODOLFO MAYOR, ESQ.
Florida Bar No.: 111647
rudy@ddpalaw.com
As Officer of the CourtDEFINITIONS AND INSTRUCTIONS
DEFINITIONS
A. “Plaintiff” shall refer to plaintiffs, PLANET T UNIFORMS, INC., including any other person
or entity acting or purporting to act on their behalf or under their control, including but not
limited to, their agents, employees and attorneys.
B. “Defendants” shall refer to defendants, FLORIDA CHARTER FOUNDATION, INC. D/B/A
FRANKLIN ACADEMY CHARTER SCHOOL, DISCOVERY SCHOOLS, INC.,
iUNIFORMS, INC., RICHARD SHELLOW, JON THOMAS ROGERS, AND SCOTT
SZNITKEN, including any other person or entity acting or purporting to act on their behalf or
under their control including, but not limited to, their agents, employees and attorneys.
C. “You” and/or “your” shall refer to you, STRATEGIC DISTRIBUTION, LP d/b/a
CLASSROOM SCHOOL UNIFORMS, including any other person or entity acting or purporting
to act on your behalf or under their control including, but not limited to, its agents, and
employees.
D. The term “person” shall refer to any natural individual in any capacity whatsoever and/or any
entity or organization, including divisions, departments, and other units herein, and shall include,
but not be limited to, public or private corporations, partnerships, joint ventures, voluntary or
unincorporated associations, organizations, proprietorships, trusts, estates, governmental
agencies, commissions, bureaus, or departments, and the agents, servants, and employees of
same.
E. The term “document” or “writing” shall refer to any medium upon which intelligence or
information can be recorded or retrieved and includes, without limitation, the original and each
copy, regardless of origin and location, of any book, pamphlet, articles, publication, brochure,
manual, periodical, letter, email, text, note, fax, statement, payment, cancelled check, prospectus,
correspondence, journal, memorandum (including any memorandum or report of a meeting or
conversation), invoice, bill, order form, receipt, voucher, check, financial statement, file,
accounting entry, instruction, schedule, shop order, diary, calendar, telex, telegram, cable, report,
record, minutes, notice, contract, agreement, study, work paper, handwritten note, draft, demand,
chart, paper, print, laboratory record, drawing sketch, diagram, form, graph, index, list, tape,
photograph, microfilm, data sheet, data processing card, or any other written, recorded,
transcribed, punched, tapes, filmed, or graphic matter, however produced and reproduced, that is
in your possession, custody or control.
F. The term “representative” shall refer to any and all agents, employees, servants, officers,
directors, or other persons acting or purporting to act on behalf of the person in question.
G. The term “evincing” or “evidencing” shall refer to having a tendency to show, prove or
disprove.
H. With respect to documents, the term “identify” shall refer to (i) state the author thereof and
the parties thereto; (ii) state its title or other identifying data; (iii) state the date of the documentor, if no date, state the exact nature and substance thereof; (iv) identify each person having
possession, care, custody or control of the original and copies thereof; and (v) if such document
was, but no longer is in your possession or subject to your control, state what disposition was
made of it.
I. With respect to “persons”, the term “identify” shall refer to: (i) state the name of the person (as
person is defined above); (ii) state the person’s business address; (iii) state the person’s residence
address; (iv) state the person’s business telephone number, and (v) state the person’s residential
telephone number.
J. The words “and” and “or” as used herein shall be construed either disjunctively, or
conjunctively, as required by the context to bring within the scope of these Interrogatories any
answer that might be deemed outside their scope by another construction.
K. “Communication” shall refer to any oral or written statement, dialogue, colloquy, discussion
or conversation, and also means any transfer of thoughts or ideas between persons by means of
documents and includes any transfer of data from one location to another by electronic or similar
means.
L. “Control” shall refer to in your possession, custody, or control or under your direction, and
includes in the possession, custody or control of those under the direction of you or your
employees, subordinates, counsel, accountant, consultant, expert, parent or affiliated corporation,
and any person purporting to act on your behalf.
M. “Related to” shall refer to directly, or indirectly, refer to, reference, reflect, describe, pertain
to, arise out of or in connection with, or in any way legally, logically, or factually be connected
with the matter discussed.
N. “Including” shall refer to including, but not limited to.
Oz. Unless otherwise specifically specified, any query with an unspecified time period shall
be deemed to be for a time period commencing December 1, 2012 through present.
INSTRUCTIONS
A. Ifyou object to producing or fail to fully produce any requested document on the
grounds of attorney-client privilege, work/product, or otherwise, you are to state
separately for each such document:(a) state the nature of the privilege;
(b) identify the specific grounds on which your objection is based;
(c) provide a privilege log as required by the Florida Rules of Civil Procedure; and
(d) answer the balance of the request which does not violate the claimed privilege.
When a Request requests the identification of any person, for each such person, state the
person's:
(a) full name; and
(b) current residential address and telephone number.
When a Request requests the identification of any document, state separately for each
such document:
(a) the title or description of the document;
(b) its date; and
(c) the person presently having custody, control or possession of the original and all
copies.
. Ifa response to any part of a request is not known, so state and provide answer to the
part known.SCHEDULE “A”
DOCUMENTS REQUESTED
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
iUNIFORMS, INC. relating to any orders placed with your company of any kind
including but not limited to any correspondence, e-mails, work orders, specifications,
contracts, inventory lists, proof of payment, product development, sampling, extensions
of credit, guarantees etc. from December 1, 2012 through present.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
RICHARD SHELLOW relating to any orders placed with your company of any kind
including but not limited to any correspondence, e-mails, work orders, specifications,
contracts, inventory lists, proof of payment, product development, sampling, extensions
of credit, guarantees etc. from December 1, 2012 through present.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
FLORIDA CHARTER FOUNDATION, INC. D/B/A FRANKLIN ACADEMY
CHARTER SCHOOL relating to any orders placed with your company of any kind
including but not limited to any correspondence, e-mails, work orders, specifications,
contracts, inventory lists, proof of payment, product development, sampling, extensions
of credit, guarantees etc. from December 1, 2012 through present.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
DISCOVERY SCHOOLS, INC. relating to any orders placed with your company of any
kind but not limited to any correspondence, e-mails, work orders, specifications,
contracts, inventory lists, proof of payment, product development, sampling, extensions
of credit, guarantees etc. from December 1, 2012 through present.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
SCOTT SZNITKEN relating to any orders placed with your company of any kind
including but not limited to any correspondence, e-mails, work orders, specifications,
contracts, inventory lists, proof of payment, product development, sampling, extensions
of credit, guarantees etc. from December 1, 2012 through present.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
JON THOMAS ROGERS relating to any orders placed with your company of any kind
including but not limited to any correspondence, e-mails, work orders, specifications,
contracts, inventory lists, proof of payment, product development, sampling, extensions
of credit, guarantees etc. from December 1, 2012 through present.10.
ll.
13.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
ELSA RODRIGUEZ relating to any orders placed with your company of any kind
including but not limited to any correspondence, e-mails, work orders, specifications,
contracts, inventory lists, proof of payment, product development, sampling, extensions
of credit, guarantees etc. from December 1, 2012 through present.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
any of the DEFENDANTS relating to the management of product development of
uniforms of any kind from December 1, 2012 through present.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
ELSA RODRIGUEZ relating to the management of product development of uniforms of
any kind from December |, 2012 through present.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
any of the DEFENDANTS relating to garment samplings for uniforms of any kind from
December 1, 2012 through present.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
ELSA RODRIGUEZ relating to garment samplings for uniforms of any kind from
December 1, 2012 through present.
All documents evidencing which of the DEFENDANTS were involved in the approval
process for any work orders with Strategic Distribution, LP d/b/a Classroom School
Uniforms.
All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and
Dr. David Thomas, M.D. J.D. relating to any orders placed with your company for
uniforms of any kind including but not limited to any correspondence, e-mails, work
orders, specifications, contracts, inventory lists, proof of payment, product development,
sampling, extensions of credit, guarantees etc. from December 1, 2012 through present.BUSINESS RECORD CERTIFICATION
Custodian of Records
I , hereby certify that I am the Custodian of Records for
. As part of my regular duties, I maintain custody of the official records
kept in the normal course and scope of regularly conducted business activities.
I hereby further certify that the records attached hereto are:
1. True and correct copies of the original made by and kept as the official business
records for
2. Were kept in the normal course and scope of the regularly conducted business
activity.
3. Were made in the regular practice in the course of the regularly conducted
business activity.
Dated 2018
AFFIANT SIGANTURE
AFFIANT PRINTED NAME
STATED OF )
SS.
COUNTY OF )
Before me this day personally appeared , who is either
personally known to me or who presented the following identification,
who being duly sworn, deposes and acknowledges that the
signature and information contained in this affidavit is true and correct.
Sworn to and subscribed before me this day of , 2018.
Notary Public — State of
My Commission Expires:
Preview
Filing # 68795539 E-Filed 03/05/2018 02:38:09 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, Vv. 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. / NOTICE OF INTENT TO SERVE SUBPOENA UNDER RULE 1.351 FOR DOCUMENTS WITHOUT DEPOSITION THE STATE OF FLORIDA: TO: YOU ARE NOTIFIED that pursuant to Rule 1.351(b), Florida Rules of Civil Procedure, after fifteen (15) days from the date of this Notice, and if no objection is received from any party, the undersigned will issue or apply to the Clerk of Court for issuance of the attached subpoena, who are not parties, directed to: STRATEGIC DISTRIBUTION, LP D/B/A CLASSROOM SCHOOL UNIFORMS 9800 DE SOTO AVE. CHATSWORTH, CA 91311 FAX: 888-283-7271 EMAIL: INFO@CLASSROOMUNIFORMS.COM. To produce the items list at the time and place specified in the Subpoena. DATED March 5, 2018. *4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/5/2018 2:38:09 PM.****CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished via Email through the Florida Courts E-Filing Portal to the service list below on Monday March 5, 2018. SERVICE LIST Christopher M. David, Esq. Respectfully Submitted, DI PIETRO PARTNERS, LLP 901 E. Las Olas Blvd., Suite 202 Fort Lauderdale, FL 33301 Primary: service@ddpalaw.com Secondary: _paralegal@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 LISANDRA ESTEVEZ, ESQ. Florida Bar No.: 111475 lisandra@ddpalaw.com RODOLFO MAYOR, ESQ. Florida Bar No.: 111647 rudy@ddpalaw.com FUERST ITTLEMAN DAVID & JOSEPH, PL 1001 Brickell Bay Drive, 32" Floor Miami, Florida 33131 Emails: cdavid@fuerstlaw.com; tdavid@fuerstlaw.com; and dmuller@fuerstlaw.com Richard Rosengarten, Esq. GREENBERG TRAURIG, P.A. 401 East Las Olas Blvd., Suite 2000 Fort Lauderdale, FL 33301 Emails: rosengartenrich@gtlaw.com; rosr@gtlaw.com; and horkyk@gtlaw.comIN 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, Defendants. / SUBPOENA DUCES TECUM WITHOUT DEPOSITION (documents may be mailed or e-mailed in lieu of appearance) THE STATE OF FLORIDA: TO: STRATEGIC DISTRIBUTION, LP D.B.A. CLASSROOM SCHOOL UNIFORMS 9800 DE SOTO AVE. CHATSWORTH, CA 91311 FAX: 888-283-7271 EMAIL: INFO@CLASSROOMUNIFORMS.COM YOU ARE COMMANDED to appear at the offices of D1 PIETRO PARTNERS, LLP 901 EAST LAS OLAS BLVD., SUITE 202, TEL: 954-712-3070 within ten (10) days of receipt of this subpoena and to have with you at that time and place the documents or objects described in Schedule “A”. The documents may be mailed or e-mailed in lieu of appearance. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this subpoena at any time before production by giving written notice to the attorney whose nameappears on this subpoena. THIS WILL NOT BE A LIVE DEPOSITION. NO TESTIMONY WILL BE TAKEN. If you fail to: (1) appear as specified; or (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena, you may be in contempt of court. You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. DATED on this __ day of , 2018. ds/ RODOLFO MAYOR, ESQ. Florida Bar No.: 111647 rudy@ddpalaw.com As Officer of the CourtDEFINITIONS AND INSTRUCTIONS DEFINITIONS A. “Plaintiff” shall refer to plaintiffs, PLANET T UNIFORMS, INC., including any other person or entity acting or purporting to act on their behalf or under their control, including but not limited to, their agents, employees and attorneys. B. “Defendants” shall refer to defendants, FLORIDA CHARTER FOUNDATION, INC. D/B/A FRANKLIN ACADEMY CHARTER SCHOOL, DISCOVERY SCHOOLS, INC., iUNIFORMS, INC., RICHARD SHELLOW, JON THOMAS ROGERS, AND SCOTT SZNITKEN, including any other person or entity acting or purporting to act on their behalf or under their control including, but not limited to, their agents, employees and attorneys. C. “You” and/or “your” shall refer to you, STRATEGIC DISTRIBUTION, LP d/b/a CLASSROOM SCHOOL UNIFORMS, including any other person or entity acting or purporting to act on your behalf or under their control including, but not limited to, its agents, and employees. D. The term “person” shall refer to any natural individual in any capacity whatsoever and/or any entity or organization, including divisions, departments, and other units herein, and shall include, but not be limited to, public or private corporations, partnerships, joint ventures, voluntary or unincorporated associations, organizations, proprietorships, trusts, estates, governmental agencies, commissions, bureaus, or departments, and the agents, servants, and employees of same. E. The term “document” or “writing” shall refer to any medium upon which intelligence or information can be recorded or retrieved and includes, without limitation, the original and each copy, regardless of origin and location, of any book, pamphlet, articles, publication, brochure, manual, periodical, letter, email, text, note, fax, statement, payment, cancelled check, prospectus, correspondence, journal, memorandum (including any memorandum or report of a meeting or conversation), invoice, bill, order form, receipt, voucher, check, financial statement, file, accounting entry, instruction, schedule, shop order, diary, calendar, telex, telegram, cable, report, record, minutes, notice, contract, agreement, study, work paper, handwritten note, draft, demand, chart, paper, print, laboratory record, drawing sketch, diagram, form, graph, index, list, tape, photograph, microfilm, data sheet, data processing card, or any other written, recorded, transcribed, punched, tapes, filmed, or graphic matter, however produced and reproduced, that is in your possession, custody or control. F. The term “representative” shall refer to any and all agents, employees, servants, officers, directors, or other persons acting or purporting to act on behalf of the person in question. G. The term “evincing” or “evidencing” shall refer to having a tendency to show, prove or disprove. H. With respect to documents, the term “identify” shall refer to (i) state the author thereof and the parties thereto; (ii) state its title or other identifying data; (iii) state the date of the documentor, if no date, state the exact nature and substance thereof; (iv) identify each person having possession, care, custody or control of the original and copies thereof; and (v) if such document was, but no longer is in your possession or subject to your control, state what disposition was made of it. I. With respect to “persons”, the term “identify” shall refer to: (i) state the name of the person (as person is defined above); (ii) state the person’s business address; (iii) state the person’s residence address; (iv) state the person’s business telephone number, and (v) state the person’s residential telephone number. J. The words “and” and “or” as used herein shall be construed either disjunctively, or conjunctively, as required by the context to bring within the scope of these Interrogatories any answer that might be deemed outside their scope by another construction. K. “Communication” shall refer to any oral or written statement, dialogue, colloquy, discussion or conversation, and also means any transfer of thoughts or ideas between persons by means of documents and includes any transfer of data from one location to another by electronic or similar means. L. “Control” shall refer to in your possession, custody, or control or under your direction, and includes in the possession, custody or control of those under the direction of you or your employees, subordinates, counsel, accountant, consultant, expert, parent or affiliated corporation, and any person purporting to act on your behalf. M. “Related to” shall refer to directly, or indirectly, refer to, reference, reflect, describe, pertain to, arise out of or in connection with, or in any way legally, logically, or factually be connected with the matter discussed. N. “Including” shall refer to including, but not limited to. Oz. Unless otherwise specifically specified, any query with an unspecified time period shall be deemed to be for a time period commencing December 1, 2012 through present. INSTRUCTIONS A. Ifyou object to producing or fail to fully produce any requested document on the grounds of attorney-client privilege, work/product, or otherwise, you are to state separately for each such document:(a) state the nature of the privilege; (b) identify the specific grounds on which your objection is based; (c) provide a privilege log as required by the Florida Rules of Civil Procedure; and (d) answer the balance of the request which does not violate the claimed privilege. When a Request requests the identification of any person, for each such person, state the person's: (a) full name; and (b) current residential address and telephone number. When a Request requests the identification of any document, state separately for each such document: (a) the title or description of the document; (b) its date; and (c) the person presently having custody, control or possession of the original and all copies. . Ifa response to any part of a request is not known, so state and provide answer to the part known.SCHEDULE “A” DOCUMENTS REQUESTED All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and iUNIFORMS, INC. relating to any orders placed with your company of any kind including but not limited to any correspondence, e-mails, work orders, specifications, contracts, inventory lists, proof of payment, product development, sampling, extensions of credit, guarantees etc. from December 1, 2012 through present. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and RICHARD SHELLOW relating to any orders placed with your company of any kind including but not limited to any correspondence, e-mails, work orders, specifications, contracts, inventory lists, proof of payment, product development, sampling, extensions of credit, guarantees etc. from December 1, 2012 through present. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and FLORIDA CHARTER FOUNDATION, INC. D/B/A FRANKLIN ACADEMY CHARTER SCHOOL relating to any orders placed with your company of any kind including but not limited to any correspondence, e-mails, work orders, specifications, contracts, inventory lists, proof of payment, product development, sampling, extensions of credit, guarantees etc. from December 1, 2012 through present. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and DISCOVERY SCHOOLS, INC. relating to any orders placed with your company of any kind but not limited to any correspondence, e-mails, work orders, specifications, contracts, inventory lists, proof of payment, product development, sampling, extensions of credit, guarantees etc. from December 1, 2012 through present. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and SCOTT SZNITKEN relating to any orders placed with your company of any kind including but not limited to any correspondence, e-mails, work orders, specifications, contracts, inventory lists, proof of payment, product development, sampling, extensions of credit, guarantees etc. from December 1, 2012 through present. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and JON THOMAS ROGERS relating to any orders placed with your company of any kind including but not limited to any correspondence, e-mails, work orders, specifications, contracts, inventory lists, proof of payment, product development, sampling, extensions of credit, guarantees etc. from December 1, 2012 through present.10. ll. 13. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and ELSA RODRIGUEZ relating to any orders placed with your company of any kind including but not limited to any correspondence, e-mails, work orders, specifications, contracts, inventory lists, proof of payment, product development, sampling, extensions of credit, guarantees etc. from December 1, 2012 through present. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and any of the DEFENDANTS relating to the management of product development of uniforms of any kind from December 1, 2012 through present. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and ELSA RODRIGUEZ relating to the management of product development of uniforms of any kind from December |, 2012 through present. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and any of the DEFENDANTS relating to garment samplings for uniforms of any kind from December 1, 2012 through present. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and ELSA RODRIGUEZ relating to garment samplings for uniforms of any kind from December 1, 2012 through present. All documents evidencing which of the DEFENDANTS were involved in the approval process for any work orders with Strategic Distribution, LP d/b/a Classroom School Uniforms. All documents between Strategic Distribution, LP d/b/a Classroom School Uniforms and Dr. David Thomas, M.D. J.D. relating to any orders placed with your company for uniforms of any kind including but not limited to any correspondence, e-mails, work orders, specifications, contracts, inventory lists, proof of payment, product development, sampling, extensions of credit, guarantees etc. from December 1, 2012 through present.BUSINESS RECORD CERTIFICATION Custodian of Records I , hereby certify that I am the Custodian of Records for . As part of my regular duties, I maintain custody of the official records kept in the normal course and scope of regularly conducted business activities. I hereby further certify that the records attached hereto are: 1. True and correct copies of the original made by and kept as the official business records for 2. Were kept in the normal course and scope of the regularly conducted business activity. 3. Were made in the regular practice in the course of the regularly conducted business activity. Dated 2018 AFFIANT SIGANTURE AFFIANT PRINTED NAME STATED OF ) SS. COUNTY OF ) Before me this day personally appeared , who is either personally known to me or who presented the following identification, who being duly sworn, deposes and acknowledges that the signature and information contained in this affidavit is true and correct. Sworn to and subscribed before me this day of , 2018. Notary Public — State of My Commission Expires: