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Filing # 43963131 E-Filed 07/14/2016 04:01:42 PM
IN THE CIRCUIT COURT OF THE 177 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.
Sey
FLORIDA CHARTER FOUNDATION, INC.,
D/B/A FRANKLIN ACADEMY CHARTER
SCHOOL,
Counter-Plaintiff,
Vv.
PLANET T UNIFORMS, INC.,
Counter-Defendant.
SSeS,
DEFENDANT/COUNTER-PLAINTIFF FLORIDA CHARTER
FOUNDATION, INC.’S SECOND 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 his request for admissions within 30 days from
the date hereof:
FUERST ITTLEMAN DAVID & JOSEPH, PL
1001 BRICKELL BAY DRIVE, 32"° FLOor, MIAMI, FL 33131 + T: 305.350.5690 + F: 305.371.8989
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/14/2016 4:01:42 PM.****CACE-14-001087 (04)
1. Admit that that the documents produced by Planet T bearing bates
numbers 1319-1434 and 1537-1569 identify all alleged trade secrets of the Plaintiff which
are at issue in this case.
2. Admit that there are no other trade secrets at issue in this case other than
those referenced in the documents produced by Planet T and marked with Bates Ranges
1319-1434 and 1537-1569.
3. Admit that PLANET T did not transmit or provide the document marked
with Bates Numbers 1431-1432 to any defendant.
4, Admit that PLANET T is not aware of any facts that would tend to
establish that any defendant obtained the document produced by Planet T marked with
Bates Numbers 1431-1432.
CERTIFICATE OF SERVICE
I certify that on July 14, 2016, a copy of the foregoing was forwarded via
electronic mail to: The Law Offices of David Di Pietro, P.A., David Di Pietro, Esq.
david@floridalitigationlawfirm.com, Nina Di Pietro, Esq., nina@floridalitigationlawfirm.com,
service@floridalitigationlawfirm.com.
Dated: July 14, 2016 FUERST ITTLEMAN DAVID & JOSEPH, PL
1001 Brickell Bay Drive, 32"4 Floor
Miami, Florida 33131
Phone: — (305) 350-5690
Fax: (305) 371-8989
Attorneys for Florida Charter Foundation, Inc.
d/b/a Franklin Academy Charter School
By: /s/Christopher M. David
CHRISTOPHER M. DAVID
Florida Bar No. 985163
cdavid@fuerstlaw.com
Thomas M. David
Florida Bar No. 20846
tdavid@fuerstlaw.com
FUERST ITTLEMAN DAVID & JOSEPH, PL
1001 BRICKELL BAY DRIVE, 32xn FLOOR, MIAMI, FL 33131 ¢ T: 305.350.5690 © F: 305.371.8989 * Www PUPRSTLAW.COM
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Filing # 43963131 E-Filed 07/14/2016 04:01:42 PM IN THE CIRCUIT COURT OF THE 177 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. Sey FLORIDA CHARTER FOUNDATION, INC., D/B/A FRANKLIN ACADEMY CHARTER SCHOOL, Counter-Plaintiff, Vv. PLANET T UNIFORMS, INC., Counter-Defendant. SSeS, DEFENDANT/COUNTER-PLAINTIFF FLORIDA CHARTER FOUNDATION, INC.’S SECOND 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 his request for admissions within 30 days from the date hereof: FUERST ITTLEMAN DAVID & JOSEPH, PL 1001 BRICKELL BAY DRIVE, 32"° FLOor, MIAMI, FL 33131 + T: 305.350.5690 + F: 305.371.8989 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/14/2016 4:01:42 PM.****CACE-14-001087 (04) 1. Admit that that the documents produced by Planet T bearing bates numbers 1319-1434 and 1537-1569 identify all alleged trade secrets of the Plaintiff which are at issue in this case. 2. Admit that there are no other trade secrets at issue in this case other than those referenced in the documents produced by Planet T and marked with Bates Ranges 1319-1434 and 1537-1569. 3. Admit that PLANET T did not transmit or provide the document marked with Bates Numbers 1431-1432 to any defendant. 4, Admit that PLANET T is not aware of any facts that would tend to establish that any defendant obtained the document produced by Planet T marked with Bates Numbers 1431-1432. CERTIFICATE OF SERVICE I certify that on July 14, 2016, a copy of the foregoing was forwarded via electronic mail to: The Law Offices of David Di Pietro, P.A., David Di Pietro, Esq. david@floridalitigationlawfirm.com, Nina Di Pietro, Esq., nina@floridalitigationlawfirm.com, service@floridalitigationlawfirm.com. Dated: July 14, 2016 FUERST ITTLEMAN DAVID & JOSEPH, PL 1001 Brickell Bay Drive, 32"4 Floor Miami, Florida 33131 Phone: — (305) 350-5690 Fax: (305) 371-8989 Attorneys for Florida Charter Foundation, Inc. d/b/a Franklin Academy Charter School By: /s/Christopher M. David CHRISTOPHER M. DAVID Florida Bar No. 985163 cdavid@fuerstlaw.com Thomas M. David Florida Bar No. 20846 tdavid@fuerstlaw.com FUERST ITTLEMAN DAVID & JOSEPH, PL 1001 BRICKELL BAY DRIVE, 32xn FLOOR, MIAMI, FL 33131 ¢ T: 305.350.5690 © F: 305.371.8989 * Www PUPRSTLAW.COM