On January 16, 2014 a
Motion,Ex Parte
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.
Preview
Filing # 41928015 E-Filed 05/24/2016 05:33:28 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.
PLAINTIFF’S, PLANET T UNIFORMS, INC., MOTION FOR EXTENSION TO
RESPOND TO DEFENDANT’S, UNIFORMS, INC.’S, REQUEST FOR PRODUCTION
COMES NOW Plaintiff, PLANET T UNIFORMS, INC. (“PLANET T”) by and through
the undersigned law firm, and file this Motion for an Extension to Respond to Defendant’s,
iUNIFORMS, INC., (“iUNIFORMS”) Request for Production, and in support of this motion
would state:
1. On or about April 18, 2016, iUNIFORMS propounded Requests for Production to
PLANET T.
2. On or about May 23, 2016, the undersigned requested an extension for PLANET
T to Respond to iUNIFORMS’ Request for Production.
3. As of today’s date, iUNIFORMS has not responded to PLANET T’s request.
Page | of 3
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/24/2016 5:33:29 PM.****4. PLANET T is in the process of compiling and preparing the necessary
information to provide a Response to the Request for Production and, as such, requests an
extension of time to respond to said discovery request.
5. This motion is not made for the purposes of delay, harassment, or any other
improper purpose.
WHEREFORE, Plaintiff, PLANET T UNIFORMS, INC., respectfully requests this
Honorable Court grant its Motion for an extension to respond to iUNIFORMS, INC.’s Request
for Production and any further relief this Court deems just and proper.
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 May 24, 2016.
DAVID DI PIETRO & ASSOCIATES
David Di Pietro Law P.A.
Tower 101
101 NE 3“ Avenue, Suite 1410
Fort Lauderdale, FL 33301
Telephone: (954) 712-3070
Facsimile: (954) 337-3824
/s/ Ashley T. Steffen
DAVID DI PIETRO, ESQ.
Florida Bar No.: 10370
david@ddpalaw.com
ASHLEY T. STEFFEN, ESQ.
Florida Bar No.: 111238
ashley@ddpalaw.com
SERVICE LIST
Christopher M. David, Esq.
Fuerst Ittleman David & J. oseph, PL
1001 Brickell Bay Drive, 32" Floor
Miami, Florida 33131
Emails: cdavid@fuerstlaw.com; tdavid@fuerstlaw.com;
Page 2 of 3And jconcepcion@fuerstlaw.com
Richard Rosengarten, Esq.
rosengartenrich@gtlaw.com; rosr@gtlaw.com
Page 3 of 3
Preview
Filing # 41928015 E-Filed 05/24/2016 05:33:28 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. PLAINTIFF’S, PLANET T UNIFORMS, INC., MOTION FOR EXTENSION TO RESPOND TO DEFENDANT’S, UNIFORMS, INC.’S, REQUEST FOR PRODUCTION COMES NOW Plaintiff, PLANET T UNIFORMS, INC. (“PLANET T”) by and through the undersigned law firm, and file this Motion for an Extension to Respond to Defendant’s, iUNIFORMS, INC., (“iUNIFORMS”) Request for Production, and in support of this motion would state: 1. On or about April 18, 2016, iUNIFORMS propounded Requests for Production to PLANET T. 2. On or about May 23, 2016, the undersigned requested an extension for PLANET T to Respond to iUNIFORMS’ Request for Production. 3. As of today’s date, iUNIFORMS has not responded to PLANET T’s request. Page | of 3 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/24/2016 5:33:29 PM.****4. PLANET T is in the process of compiling and preparing the necessary information to provide a Response to the Request for Production and, as such, requests an extension of time to respond to said discovery request. 5. This motion is not made for the purposes of delay, harassment, or any other improper purpose. WHEREFORE, Plaintiff, PLANET T UNIFORMS, INC., respectfully requests this Honorable Court grant its Motion for an extension to respond to iUNIFORMS, INC.’s Request for Production and any further relief this Court deems just and proper. 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 May 24, 2016. DAVID DI PIETRO & ASSOCIATES David Di Pietro Law P.A. Tower 101 101 NE 3“ Avenue, Suite 1410 Fort Lauderdale, FL 33301 Telephone: (954) 712-3070 Facsimile: (954) 337-3824 /s/ Ashley T. Steffen DAVID DI PIETRO, ESQ. Florida Bar No.: 10370 david@ddpalaw.com ASHLEY T. STEFFEN, ESQ. Florida Bar No.: 111238 ashley@ddpalaw.com SERVICE LIST Christopher M. David, Esq. Fuerst Ittleman David & J. oseph, PL 1001 Brickell Bay Drive, 32" Floor Miami, Florida 33131 Emails: cdavid@fuerstlaw.com; tdavid@fuerstlaw.com; Page 2 of 3And jconcepcion@fuerstlaw.com Richard Rosengarten, Esq. rosengartenrich@gtlaw.com; rosr@gtlaw.com Page 3 of 3