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Filing # 67956043 E-Filed 02/14/2018 01:05:18 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.
/
PLANET T UNIFORMS, INC.’S FIRST SET OF INTERROGATORIES
TO DEFENDANT, ROGER SHELLOW
COMES NOW Plaintiff, PLANET T UNIFORMS, INC., (“PLANET T”), by and
through its undersigned attorneys, and hereby propound this its First Set of Interrogatories to
Defendant, ROGER SHELLOW, (“SHELLOW”) pursuant to Florida Rules of Civil Procedure
1.340 due to the undersigned counsel within thirty (30) days of the service of this request at the
offices of Plaintiff's attorney, DI PIETRO PARTNERS, LLP, at 901 E. Las Olas Blvd., Suite
202, Fort Lauderdale, FL 33301.
SEE THE ATTACHED SCHEDULE “A”
Page | of 8
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/14/2018 1:05:18 PM.****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 February 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
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
SERVICE 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; muehlfeldern@gtlaw.com
rosengartenrich@gtlaw.com; rosr@gtlaw.com
Page 2 of 8DEFINITIONS AND INSTRUCTIONS
The following definitions apply throughout these Interrogatories:
1. "Plaintiff" means PLANET T UNIFORMS, INC., and shall include any other person or entity,
their employees, representatives, successors, servants, agents, affiliates, partners, successors or
assigns and/or any person acting or purporting to act on her behalf.
2. "You" or "Your" means the party to whom this request is directed, and shall include
employees, representatives, agents, attorneys, successors, heirs, assigns and any person acting or
purporting to act on his or her behalf.
3. "Person" or “Individual” means any natural person, public or private corporation,
governmental entity, partnership, association, cooperative, joint venture, sole proprietorship, or
other legal entity.
4. "Document, documents or documentation" include writings of every kind, including, but not
limited to, any letter, book, record, report, file, file folder, envelope, label, memorandum,
correspondence, communication, summary, note, announcement, minute, study, telephone
message, transmittal slip, printed literature, diary, appointment book, calendar, minute book,
statistical compilation, graph, facsimile, analysis, telegram, telex, cable, working paper, journal,
book of account, ledger, journal, spread sheet, audit, control sheet, drawing, draft, chart,
schedule, photograph, phono record, tape, disk, card, wire, computer program, computer
printout, and any other electronic or mechanical recording or transcript of any other instrument
or device from which information can be perceived, or which is used to memorialize human
thought, speech or action, in the possession, custody or control of Defendant, her agents,
employees, representatives, attorneys, accountants, or anyone else acting on her behalf, wherever
located. The term "document" also includes copies containing information in addition to that
contained on the original, and all the attachments, enclosures or documents referred to in any
documents produced pursuant to the request. If any tape, disk, card, wire or other electronic or
mechanical recording or transcript or any computer program is produced, shall also produce such
documents as are necessary for the decoding, playing back, printing out and/or interpretation
thereof, or any other documents which are necessary to convert such information into a useful
and useable format.
5. “Relate”, "regard", or any permutation thereof means that which is, constitutes, compromises,
discloses, reflects, describes, discusses, concerns, supports, contradicts or in any other manner
Page 3 of 8touches upon.
6. “Identify” or “identity” when used in reference to:
a)
b)
c)
d)
e)
A natural individual, means to state his or her full name, title, residential and
business addresses, and telephone numbers;
A corporation, means to state its full corporate name and any names under which
it does business, state of incorporation, the address of its principal place of
business, and the address of all its officers in Florida;
A business, means to state the full name or style under which the business is
conducted, its business address or addresses, the types of businesses in which it is
engaged, the geographic areas in which it conducts those businesses, and the
identity of the person or persons who own, operate and control the business;
A document, means to state the number of pages and the nature of the document
(e.g., letter or memorandum), its title, date, the name or names of its author(s) and
recipient(s) and its present location and custodian(s);
A communication, if any part of the communication is written, means to identify
the document(s) which refers to or evidences the communication, and, to the
extent that the communication was unwritten, to identify the persons participating
in the communication and to state the date, manner, place and substance of the
communication
INSTRUCTIONS
1. Unless otherwise specifically indicated in any individual interrogatory, the time period to
which these interrogatories relate is the period from December 1, 2012 to the present. However,
this request shall be interpreted to require supplemental answers or production to the extent that
you acquire information or other documents after responding to these requests which make your
initial answers incorrect, incomplete or no longer true.
2. If you object in any part to any interrogatory, please respond to the interrogatories or portions
thereof to which you do not object, and state your objection to the remainder.
Page 4 of 83. Each Interrogatory and part thereof, shall be answered separately, fully and completely,
without reference to any answer of any other Interrogatory.
4. With respect to information or documents as to which you may claim privilege, attorney’s
work product or trial preparation materials, you are requested to identify each such document, in
writing, on or before the date of the production set forth herein, together with the following
information: the nature, date, subject matter and author of the document, as well as the identity
of all persons to whom the document was directed, addressed or received, and the paragraphs of
the discovery requests to which the document corresponds. For each such document, you are
further required to state the basis for your claim of privilege, attorney’s work product, or trial
preparation materials.
FIRST INTERROGATORIES TO DEFENDANT
Please state the full name, address, and phone number of the person answering these
interrogatories.
ANSWER:
List all former names and when you were known by those names. State all addresses
where you have lived for the past 10 years, the dates you lived at each address, and your
date of birth.
ANSWER:
Please describe every conversation you had regarding the formation of UNIFORMS, Inc.
prior to its incorporation, including but not limited to, conversations with persons
regarding the registration and incorporation of the corporation with the State of Florida
and whose idea it was to name Robert Shellow as the incorporator of the corporation.
ANSWER:
Please describe every conversation you had regarding the business model and concept of
iUNIFORMS, Inc. prior to its incorporation including but not limited to who’s idea it was
to go into the uniforms business and discussions about each person’s role would be in the
corporation.
ANSWER:
Page 5 of 8Please describe in detail your affiliation, title, role and responsibilities, either current or
former, with i\UNIFORMS, Inc.
ANSWER:
Please describe in detail your affiliation, title, role and responsibilities, either current or
former, with FRANKLIN.
ANSWER:
Please describe in detail your affiliation, title, role and responsibilities, either current or
former, with DISCOVERY SCHOOLS, INC.,
ANSWER:
List the names and contact information of every individual that assisted or participated, in
any capacity, in the creation, formation, concept, development or content of
iUNIFORMS’ website? Please describe in detail their contributions including but not
limited to their involvement in obtaining Perfect Privacy for the corporation’s website.
This list should include yourself if applicable.
ANSWER:
List the names and contact information of every individual that assisted in transferring,
conveying or assigning the ownership for the domain “iUNIFORMS.com” from
DISCOVERY SCHOOLS to iUNIFORMS?
ANSWER:
. Have you ever seen or been provided uniform sales reports, contract(s), size charts
prepared by PLANET T? If yes, please explain the date you saw or were provided same,
who showed you or provided same, and the purpose of same.
ANSWER:
. Identify every capital contribution, loan, gift or any other service of value that you have
provided to iUNIFORMS, Inc.
ANSWER:
Page 6 of 8. Identify every payment, distribution, gift received from iUNIFORMS and include the
date(s) such profit/compensation/monies was received, the type/amount of
profit/compensation/monies received, and the purpose of the profit/compensation/monies
received.
ANSWER:
. Describe your specific qualifications, experience, credentials and work history in the
uniforms industry.
ANSWER:
. Have you ever received a profit, compensation, or monies from DISCOVERY
SCHOOLS related to iUNIFORMS? If so, please provide the date(s) such
profit/compensation/monies was received, the type/amount of
profit/compensation/monies received, and the purpose of the profit/compensation/monies
received.
ANSWER:
. Have you ever seen or been provided sales reports, contract(s), size charts prepared by
PLANET T, with mention of PLANET T, or regarding PLANET T? If yes, please
explain the date you saw or were provided same, who showed you or provided same, and
the purpose of same.
ANSWER:
. Please describe every conversation you had with JON THOMAS ROGERS regarding the
uniform services provided by iUNIFORMS to FRANKLIN from December 1, 2012
through January 16, 2014. Include the date(s) of the conversation(s), the persons who
were privy to the conversation and whether that conversation was had orally or in
writing.
ANSWER:
. Please describe every conversation you had with SCOTT SZNITKEN regarding the
uniform services provided by iUNIFORMS to FRANKLIN from December 1, 2012
through January 16, 2014. Include the date(s) of the conversation(s), the persons who
Page 7 of 820.
2
22.
23.
were privy to the conversation and whether that conversation was had orally or in
writing.
ANSWER:
. Please describe every conversation you had with anyone at iUNIFORMS regarding the
uniform services provided by iUNIFORMS to FRANKLIN from December 1, 2012
through January 16, 2014. Include the date(s) of the conversation(s), the persons who
were privy to the conversation and whether that conversation was had orally or in
writing.
ANSWER:
. Please describe every conversation you had with anyone at FRANKLIN regarding the
uniform services provided by iUNIFORMS to FRANKLIN from December 1, 2012
through January 16, 2014. Include the date(s) of the conversation(s), the persons who
were privy to the conversation and whether that conversation was had orally or in
writing.
ANSWER:
Please explain the reasons and circumstances surrounding your request for PLANET T’s
sales, margins and uniforms information.
ANSWER:
. Please describe any and all conversations where the reasons and circumstances
surrounding FRANKLIN’s decision to reissue a call for proposals for uniforms for the
2012-2013 school year were discussed, the identity and contact information of the
individuals who participated in those conversations and whether those conversation were
had orally or in writing.
ANSWER:
Provide a list of persons that you shared or disseminated the information provided by
PLANET T which PLANET T alleges to been confidential business information
protected by trade secrets. In your answer include their names, e-mails addresses,
telephone number.
ANSWER:
Identify each and every person that assisted in the preparation, drafting or negotiating of
a contract between iUNIFORMS, Inc. and FRANKLIN.
ANSWER:
Page 8 of 8
Preview
Filing # 67956043 E-Filed 02/14/2018 01:05:18 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. / PLANET T UNIFORMS, INC.’S FIRST SET OF INTERROGATORIES TO DEFENDANT, ROGER SHELLOW COMES NOW Plaintiff, PLANET T UNIFORMS, INC., (“PLANET T”), by and through its undersigned attorneys, and hereby propound this its First Set of Interrogatories to Defendant, ROGER SHELLOW, (“SHELLOW”) pursuant to Florida Rules of Civil Procedure 1.340 due to the undersigned counsel within thirty (30) days of the service of this request at the offices of Plaintiff's attorney, DI PIETRO PARTNERS, LLP, at 901 E. Las Olas Blvd., Suite 202, Fort Lauderdale, FL 33301. SEE THE ATTACHED SCHEDULE “A” Page | of 8 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/14/2018 1:05:18 PM.****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 February 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 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 SERVICE 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; muehlfeldern@gtlaw.com rosengartenrich@gtlaw.com; rosr@gtlaw.com Page 2 of 8DEFINITIONS AND INSTRUCTIONS The following definitions apply throughout these Interrogatories: 1. "Plaintiff" means PLANET T UNIFORMS, INC., and shall include any other person or entity, their employees, representatives, successors, servants, agents, affiliates, partners, successors or assigns and/or any person acting or purporting to act on her behalf. 2. "You" or "Your" means the party to whom this request is directed, and shall include employees, representatives, agents, attorneys, successors, heirs, assigns and any person acting or purporting to act on his or her behalf. 3. "Person" or “Individual” means any natural person, public or private corporation, governmental entity, partnership, association, cooperative, joint venture, sole proprietorship, or other legal entity. 4. "Document, documents or documentation" include writings of every kind, including, but not limited to, any letter, book, record, report, file, file folder, envelope, label, memorandum, correspondence, communication, summary, note, announcement, minute, study, telephone message, transmittal slip, printed literature, diary, appointment book, calendar, minute book, statistical compilation, graph, facsimile, analysis, telegram, telex, cable, working paper, journal, book of account, ledger, journal, spread sheet, audit, control sheet, drawing, draft, chart, schedule, photograph, phono record, tape, disk, card, wire, computer program, computer printout, and any other electronic or mechanical recording or transcript of any other instrument or device from which information can be perceived, or which is used to memorialize human thought, speech or action, in the possession, custody or control of Defendant, her agents, employees, representatives, attorneys, accountants, or anyone else acting on her behalf, wherever located. The term "document" also includes copies containing information in addition to that contained on the original, and all the attachments, enclosures or documents referred to in any documents produced pursuant to the request. If any tape, disk, card, wire or other electronic or mechanical recording or transcript or any computer program is produced, shall also produce such documents as are necessary for the decoding, playing back, printing out and/or interpretation thereof, or any other documents which are necessary to convert such information into a useful and useable format. 5. “Relate”, "regard", or any permutation thereof means that which is, constitutes, compromises, discloses, reflects, describes, discusses, concerns, supports, contradicts or in any other manner Page 3 of 8touches upon. 6. “Identify” or “identity” when used in reference to: a) b) c) d) e) A natural individual, means to state his or her full name, title, residential and business addresses, and telephone numbers; A corporation, means to state its full corporate name and any names under which it does business, state of incorporation, the address of its principal place of business, and the address of all its officers in Florida; A business, means to state the full name or style under which the business is conducted, its business address or addresses, the types of businesses in which it is engaged, the geographic areas in which it conducts those businesses, and the identity of the person or persons who own, operate and control the business; A document, means to state the number of pages and the nature of the document (e.g., letter or memorandum), its title, date, the name or names of its author(s) and recipient(s) and its present location and custodian(s); A communication, if any part of the communication is written, means to identify the document(s) which refers to or evidences the communication, and, to the extent that the communication was unwritten, to identify the persons participating in the communication and to state the date, manner, place and substance of the communication INSTRUCTIONS 1. Unless otherwise specifically indicated in any individual interrogatory, the time period to which these interrogatories relate is the period from December 1, 2012 to the present. However, this request shall be interpreted to require supplemental answers or production to the extent that you acquire information or other documents after responding to these requests which make your initial answers incorrect, incomplete or no longer true. 2. If you object in any part to any interrogatory, please respond to the interrogatories or portions thereof to which you do not object, and state your objection to the remainder. Page 4 of 83. Each Interrogatory and part thereof, shall be answered separately, fully and completely, without reference to any answer of any other Interrogatory. 4. With respect to information or documents as to which you may claim privilege, attorney’s work product or trial preparation materials, you are requested to identify each such document, in writing, on or before the date of the production set forth herein, together with the following information: the nature, date, subject matter and author of the document, as well as the identity of all persons to whom the document was directed, addressed or received, and the paragraphs of the discovery requests to which the document corresponds. For each such document, you are further required to state the basis for your claim of privilege, attorney’s work product, or trial preparation materials. FIRST INTERROGATORIES TO DEFENDANT Please state the full name, address, and phone number of the person answering these interrogatories. ANSWER: List all former names and when you were known by those names. State all addresses where you have lived for the past 10 years, the dates you lived at each address, and your date of birth. ANSWER: Please describe every conversation you had regarding the formation of UNIFORMS, Inc. prior to its incorporation, including but not limited to, conversations with persons regarding the registration and incorporation of the corporation with the State of Florida and whose idea it was to name Robert Shellow as the incorporator of the corporation. ANSWER: Please describe every conversation you had regarding the business model and concept of iUNIFORMS, Inc. prior to its incorporation including but not limited to who’s idea it was to go into the uniforms business and discussions about each person’s role would be in the corporation. ANSWER: Page 5 of 8Please describe in detail your affiliation, title, role and responsibilities, either current or former, with i\UNIFORMS, Inc. ANSWER: Please describe in detail your affiliation, title, role and responsibilities, either current or former, with FRANKLIN. ANSWER: Please describe in detail your affiliation, title, role and responsibilities, either current or former, with DISCOVERY SCHOOLS, INC., ANSWER: List the names and contact information of every individual that assisted or participated, in any capacity, in the creation, formation, concept, development or content of iUNIFORMS’ website? Please describe in detail their contributions including but not limited to their involvement in obtaining Perfect Privacy for the corporation’s website. This list should include yourself if applicable. ANSWER: List the names and contact information of every individual that assisted in transferring, conveying or assigning the ownership for the domain “iUNIFORMS.com” from DISCOVERY SCHOOLS to iUNIFORMS? ANSWER: . Have you ever seen or been provided uniform sales reports, contract(s), size charts prepared by PLANET T? If yes, please explain the date you saw or were provided same, who showed you or provided same, and the purpose of same. ANSWER: . Identify every capital contribution, loan, gift or any other service of value that you have provided to iUNIFORMS, Inc. ANSWER: Page 6 of 8. Identify every payment, distribution, gift received from iUNIFORMS and include the date(s) such profit/compensation/monies was received, the type/amount of profit/compensation/monies received, and the purpose of the profit/compensation/monies received. ANSWER: . Describe your specific qualifications, experience, credentials and work history in the uniforms industry. ANSWER: . Have you ever received a profit, compensation, or monies from DISCOVERY SCHOOLS related to iUNIFORMS? If so, please provide the date(s) such profit/compensation/monies was received, the type/amount of profit/compensation/monies received, and the purpose of the profit/compensation/monies received. ANSWER: . Have you ever seen or been provided sales reports, contract(s), size charts prepared by PLANET T, with mention of PLANET T, or regarding PLANET T? If yes, please explain the date you saw or were provided same, who showed you or provided same, and the purpose of same. ANSWER: . Please describe every conversation you had with JON THOMAS ROGERS regarding the uniform services provided by iUNIFORMS to FRANKLIN from December 1, 2012 through January 16, 2014. Include the date(s) of the conversation(s), the persons who were privy to the conversation and whether that conversation was had orally or in writing. ANSWER: . Please describe every conversation you had with SCOTT SZNITKEN regarding the uniform services provided by iUNIFORMS to FRANKLIN from December 1, 2012 through January 16, 2014. Include the date(s) of the conversation(s), the persons who Page 7 of 820. 2 22. 23. were privy to the conversation and whether that conversation was had orally or in writing. ANSWER: . Please describe every conversation you had with anyone at iUNIFORMS regarding the uniform services provided by iUNIFORMS to FRANKLIN from December 1, 2012 through January 16, 2014. Include the date(s) of the conversation(s), the persons who were privy to the conversation and whether that conversation was had orally or in writing. ANSWER: . Please describe every conversation you had with anyone at FRANKLIN regarding the uniform services provided by iUNIFORMS to FRANKLIN from December 1, 2012 through January 16, 2014. Include the date(s) of the conversation(s), the persons who were privy to the conversation and whether that conversation was had orally or in writing. ANSWER: Please explain the reasons and circumstances surrounding your request for PLANET T’s sales, margins and uniforms information. ANSWER: . Please describe any and all conversations where the reasons and circumstances surrounding FRANKLIN’s decision to reissue a call for proposals for uniforms for the 2012-2013 school year were discussed, the identity and contact information of the individuals who participated in those conversations and whether those conversation were had orally or in writing. ANSWER: Provide a list of persons that you shared or disseminated the information provided by PLANET T which PLANET T alleges to been confidential business information protected by trade secrets. In your answer include their names, e-mails addresses, telephone number. ANSWER: Identify each and every person that assisted in the preparation, drafting or negotiating of a contract between iUNIFORMS, Inc. and FRANKLIN. ANSWER: Page 8 of 8