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Filing # 43345889 E-Filed 06/28/2016 06:51:03 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-14-001087(02)
PLANET T UNIFORMS, INC.,
Plaintiff,
vs.
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.
/
DEFENDANT, IUNIFORMS INC.’S RESPONSES TO PLANET T UNIFORMS, INC.’S
FIRST REQUEST FOR PRODUCTION TO DEFENDANT
Defendant, iUniforms, Inc. (“iUniforms”), by and through undersigned counsel, and
pursuant to Florida Rule of Civil Procedure 1.350, hereby serves its Responses and Objections to
Plaintiff, Planet T Uniforms, Inc.’s (“Planet T”) First Request for Production on Defendant,
iUniforms.
OBJECTIONS AND RESPONSES TO EACH REQUEST
REQUEST NO. 1
1. Any and all contracts between you and FLORIDA CHARTER FOUNDATION,
INC. d/b/a FRANKLIN ACADEMY CHARTER (“FRANKLIN”).
RESPONSE: See documents iUniforms previously produced to Planet T, identified by
Bates range iU_00411U_0048.
REQUEST NO. 2
2. Any and all contracts between you and FLORIDA CHARTER FOUNDATION,
INC.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 6/28/2016 6:51:02 PM.****RESPONSE: See documents iUniforms previously produced to Planet T, identified by
Bates range iU_0041-iU_0048.
REQUEST NO. 3
3. Any and all correspondence between you and FRANKLIN.
RESPONSE: iUniforms objects to Request No. 3 as overbroad, unlimited as to time or
scope, and seeking information irrelevant to the subject matter of the above-styled
action. Additionally, producing all correspondence responsive to this Request would
require the review of voluminous irrelevant materials containing confidential
information such as customer names, phone numbers, e-mail addresses, and credit
card information; such review and redaction would be overly burdensome, particularly
in view of the irrelevance of such materials. 1Uniforms further objects to this request
to the extent it seeks privileged communications, including those protected by a joint
defense agreement, or attorney work product. Subject to these objections, iUniforms
will produce non-privileged responsive correspondence, as they are kept in the usual
course of business, identified by Bates ranges iU_0050 & iU_0077-i1U_0385.
REQUEST NO. 4
4. Any and all documents between you and FRANKLIN regarding services provided
to FRANKLIN for the 2012-2013 school year.
RESPONSE: iUniforms objects to Request No. 4 as overbroad and as seeking
information irrelevant to the subject matter of the above-styled action. iUniforms
further objects to this request to the extent it seeks privileged communications,
including those protected by a joint defense agreement, or attorney work product.
iUniforms further objects to Request No. 4 as vague, in that it seeks documents
regarding services provided to Franklin without identifying by whom. Subject to these
objections, and assuming that this Request seeks documents between iUniforms and
Franklin regarding services provided by iUniforms to Franklin for the 2012-2013
school year, iUniforms states that after a diligent search it is currently unaware of any
such documents in its possession, custody, or control. iUniforms first began servicing
Franklin for the 2013-2014 school year.
REQUEST NO. 5
5. Any and all documents received from a party to this action, or other third parties
which relates to PLANET T’s services provided to FRANKLIN.
RESPONSE: iUniforms objects to Request No. 5 as overbroad, unlimited as to time or
scope, and seeking information irrelevant to the subject matter of the above-styled
action. iUniforms further objects to this request to the extent it seeks privileged
communications, including those protected by a joint defense agreement, or attorney
work product. Subject to these objections, iUniforms will produce responsive documents,
2if any, presently known to exist, as they are kept in the usual course of business, identified
by Bates ranges iU_0050 & iU_0077-iU_0385.
REQUEST NO. 6
6. Any and all documents provided to a party to this action, or other third parties
which relates to PLANET T’s services provided to FRANKLIN.
RESPONSE: iUniforms objects to Request No. 6 as overbroad, unlimited as to time or
scope, and seeking information irrelevant to the subject matter of the above-styled
action. iUniforms further objects to this request to the extent it seeks privileged
communications, including those protected by a joint defense agreement, or attorney
work product. Subject to these objections, iUniforms will produce responsive documents,
if any, presently known to exist, as they are kept in the usual course of business, identified
by Bates ranges iU_0050 & iU_0077-iU_0385.
REQUEST NO. 7
7. Any and all documents received from a party to this action, or other third parties
which has PLANET T’s name on it.
RESPONSE: iUniforms objects to Request No. 7 as overbroad, unlimited as to time or
scope, and seeking information irrelevant to the subject matter of the above-styled
action. iUniforms further objects to this request to the extent it seeks privileged
communications, including those protected by a joint defense agreement, or attorney
work product. Subject to these objections, iUniforms will produce responsive
documents, if any, as they are kept in the usual course of business, identified by Bates
ranges iU_0050 & iU_0077-iU_0385.
REQUEST NO. 8
8. Any and all documents provided to a party to this action, or other third parties
which has PLANET T’s name on it.
RESPONSE: iUniforms objects to Request No. 8 as overbroad, unlimited as to time or
scope, and seeking information irrelevant to the subject matter of the above-styled
action. iUniforms further objects to this request to the extent it seeks privileged
communications, including those protected by a joint defense agreement, or attorney
work product. Subject to these objections, iUniforms will produce responsive
documents, if any, as they are kept in the usual course of business, identified by Bates
ranges iU_0050 & iU_0077-iU_0385.
0.9
9! Any and all documents received from a party to this action, or other third parties
3regarding PLANET T, including but not limited to, sales reports, size charts, invoices, email
correspondences and contracts.
RESPONSE: iUniforms objects to Request No. 9 as overbroad, unlimited as to time or
scope, and seeking information irrelevant to the subject matter of the above-styled
action. iUniforms further objects to this request to the extent it seeks privileged
communications, including those protected by a joint defense agreement, or attorney
work product. Subject to these objections, iUniforms will produce responsive
documents, if any, as they are kept in the usual course of business, identified by Bates
ranges iU_0050 & iU_0077-iU_0385.
REQUEST NO. 10
10. Any and all documents provided to a party to this action, or other third parties
regarding PLANET T, including but not limited to, sales reports, size charts, invoices, email
correspondences and contracts.
RESPONSE: iUniforms objects to Request No. 10 as overbroad, unlimited as to time
or scope, and seeking information irrelevant to the subject matter of the above-styled
action. iUniforms further objects to this request to the extent it seeks privileged
communications, including those protected by a joint defense agreement, or attorney
work product. Subject to these objections, iUniforms will produce responsive
documents, if any, as they are kept in the usual course of business, identified by Bates
ranges iU_0050 & iU_0077-iU_0385.
REQUEST NO. 11
11. Any and all documents regarding complaints related to, evidence or reference
iUNIFORMS’ services or products for FRANKLIN.
RESPONSE: iUniforms objects to Request No. 11 as overbroad, unlimited as to time
or scope, and seeking information irrelevant to the subject matter of the above-styled
action. Additionally, producing all documents responsive to this Request would
require the review of voluminous irrelevant materials containing confidential
information such as customer names, phone numbers, e-mail addresses, and credit
card information; such review and redaction would be overly burdensome, particularly
in view of the irrelevance of such materials. iUniforms further objects to this request
to the extent it seeks privileged communications, including those protected by a joint
defense agreement, or attorney work product. Subject to these objections, iUniforms
will produce non-privileged responsive documents as they are kept in the usual course of
business, identified by Bates ranges iU_0050 & iU_0077—iU_0385.REQUEST NO. 12
12. All correspondence regarding or with mention of PLANET T, Maria Trotto, or
Moshe Trotto.
RESPONSE: iUniforms objects to Request No. 12 as overbroad, unlimited in time or
scope, and seeking information irrelevant to the subject matter of the above-styled
action, iUniforms further objects to this request to the extent it seeks privileged
communications, including those protected by a joint defense agreement, or attorney
work product. Subject to these objections, iUniforms will produce non-privileged
responsive correspondence, as they are kept in the usual course of business, regarding or
with mention of Planet T, identified by Bates Range iU_0050 & iU_0077i1U_0385. After
a diligent search, iUniforms is currently unaware of any responsive, non-privileged
correspondence regarding or with mention of Maria Trotto or Moshe Trotto in its
possession, custody, or control.
REQUEST NO. 13
13. Any and all documents related to, evidence or reference profit sharing between
FRANKLIN and iUNIFORMS.
RESPONSE: iUniforms objects to Request No. 13 as seeking documents irrelevant to
the subject matter of the above-styled action. iUniforms further objects to this Request
to the extent it seeks privileged communications, including those protected by a joint
defense agreement, or attorney work product. Subject to these objections, iUniforms
states that, after a diligent search, iUniforms is currently unaware of any responsive
documents in its possession, custody, or control.
REQUEST NO. 14
14. All documents (excluding attorney client communication and work product)
iUNIFORMS relied upon in preparing its Motion to Dismiss.
RESPONSE: iUniforms objects to this Request to the extent it seeks privileged
communications, including those protected by a joint defense agreement, or attorney
work product. Subject to these objections, iUniforms is currently unaware of any
responsive documents in its possession, custody, or control.
REQUEST NO. 15
15. All documents used or reviewed in anticipation of incorporating UNIFORMS.
RESPONSE: iUniforms objects to Request No. 15 as seeking documents irrelevant to
the subject matter of the above-styled action. iUniforms further objects to this Request
to the extent it seeks privileged communications, including those protected by a joint
5defense agreement, or attorney work product. Subject to these objections, iUniforms
will produce all non-privileged, responsive documents presently known to exist and within
its possession, custody or control, identified by Bates range iU_0386-iU_0387.
REQUEST NO. 16
16. Any and all documents or materials used to create i\UNIFORMS’ website.
RESPONSE: iUniforms objects to Request No. 16 as seeking documents irrelevant to
the subject matter of the above-styled action. iUniforms further objects to this Request
to the extent it seeks privileged communications, including those protected by a joint
defense agreement, or attorney work product. Subject to these objections, iUniforms
will produce all non-privileged, responsive documents presently known to exist and within
its possession, custody or control, identified by Bates range iU_0051-iU_0076.
Respectfully Submitted,
GREENBERG TRAURIG, P.A.
Attorneys for Defendant iUniforms, Inc.
401 East Las Olas Boulevard
Suite 2000
Fort Lauderdale, Florida 33301
Telephone: (954) 765-0500
Telefax: (954) 765-1477
By: __/s/Richard Rosengarten
KENNETH A. HORKY
Florida Bar Number 691194
HorkyK@gtlaw.com
(€gtlaw.com
gtlaw.com
RICHARD ROSENGARTEN
Florida Bar Number 0106169
RosengartenRich@gtlaw.com
@gtlaw.comCERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing document was electronically filed in this action on
June 28, 2016, through the Florida Courts E-filing Portal, and that the Portal was used as a means
to serve the e-filed document upon all counsel and parties on the service list associated with this
action.
By: ___/s/Richard Rosengarten
RICHARD ROSENGARTEN
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Filing # 43345889 E-Filed 06/28/2016 06:51:03 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-14-001087(02) PLANET T UNIFORMS, INC., Plaintiff, vs. 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. / DEFENDANT, IUNIFORMS INC.’S RESPONSES TO PLANET T UNIFORMS, INC.’S FIRST REQUEST FOR PRODUCTION TO DEFENDANT Defendant, iUniforms, Inc. (“iUniforms”), by and through undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby serves its Responses and Objections to Plaintiff, Planet T Uniforms, Inc.’s (“Planet T”) First Request for Production on Defendant, iUniforms. OBJECTIONS AND RESPONSES TO EACH REQUEST REQUEST NO. 1 1. Any and all contracts between you and FLORIDA CHARTER FOUNDATION, INC. d/b/a FRANKLIN ACADEMY CHARTER (“FRANKLIN”). RESPONSE: See documents iUniforms previously produced to Planet T, identified by Bates range iU_00411U_0048. REQUEST NO. 2 2. Any and all contracts between you and FLORIDA CHARTER FOUNDATION, INC. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 6/28/2016 6:51:02 PM.****RESPONSE: See documents iUniforms previously produced to Planet T, identified by Bates range iU_0041-iU_0048. REQUEST NO. 3 3. Any and all correspondence between you and FRANKLIN. RESPONSE: iUniforms objects to Request No. 3 as overbroad, unlimited as to time or scope, and seeking information irrelevant to the subject matter of the above-styled action. Additionally, producing all correspondence responsive to this Request would require the review of voluminous irrelevant materials containing confidential information such as customer names, phone numbers, e-mail addresses, and credit card information; such review and redaction would be overly burdensome, particularly in view of the irrelevance of such materials. 1Uniforms further objects to this request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms will produce non-privileged responsive correspondence, as they are kept in the usual course of business, identified by Bates ranges iU_0050 & iU_0077-i1U_0385. REQUEST NO. 4 4. Any and all documents between you and FRANKLIN regarding services provided to FRANKLIN for the 2012-2013 school year. RESPONSE: iUniforms objects to Request No. 4 as overbroad and as seeking information irrelevant to the subject matter of the above-styled action. iUniforms further objects to this request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. iUniforms further objects to Request No. 4 as vague, in that it seeks documents regarding services provided to Franklin without identifying by whom. Subject to these objections, and assuming that this Request seeks documents between iUniforms and Franklin regarding services provided by iUniforms to Franklin for the 2012-2013 school year, iUniforms states that after a diligent search it is currently unaware of any such documents in its possession, custody, or control. iUniforms first began servicing Franklin for the 2013-2014 school year. REQUEST NO. 5 5. Any and all documents received from a party to this action, or other third parties which relates to PLANET T’s services provided to FRANKLIN. RESPONSE: iUniforms objects to Request No. 5 as overbroad, unlimited as to time or scope, and seeking information irrelevant to the subject matter of the above-styled action. iUniforms further objects to this request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms will produce responsive documents, 2if any, presently known to exist, as they are kept in the usual course of business, identified by Bates ranges iU_0050 & iU_0077-iU_0385. REQUEST NO. 6 6. Any and all documents provided to a party to this action, or other third parties which relates to PLANET T’s services provided to FRANKLIN. RESPONSE: iUniforms objects to Request No. 6 as overbroad, unlimited as to time or scope, and seeking information irrelevant to the subject matter of the above-styled action. iUniforms further objects to this request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms will produce responsive documents, if any, presently known to exist, as they are kept in the usual course of business, identified by Bates ranges iU_0050 & iU_0077-iU_0385. REQUEST NO. 7 7. Any and all documents received from a party to this action, or other third parties which has PLANET T’s name on it. RESPONSE: iUniforms objects to Request No. 7 as overbroad, unlimited as to time or scope, and seeking information irrelevant to the subject matter of the above-styled action. iUniforms further objects to this request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms will produce responsive documents, if any, as they are kept in the usual course of business, identified by Bates ranges iU_0050 & iU_0077-iU_0385. REQUEST NO. 8 8. Any and all documents provided to a party to this action, or other third parties which has PLANET T’s name on it. RESPONSE: iUniforms objects to Request No. 8 as overbroad, unlimited as to time or scope, and seeking information irrelevant to the subject matter of the above-styled action. iUniforms further objects to this request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms will produce responsive documents, if any, as they are kept in the usual course of business, identified by Bates ranges iU_0050 & iU_0077-iU_0385. 0.9 9! Any and all documents received from a party to this action, or other third parties 3regarding PLANET T, including but not limited to, sales reports, size charts, invoices, email correspondences and contracts. RESPONSE: iUniforms objects to Request No. 9 as overbroad, unlimited as to time or scope, and seeking information irrelevant to the subject matter of the above-styled action. iUniforms further objects to this request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms will produce responsive documents, if any, as they are kept in the usual course of business, identified by Bates ranges iU_0050 & iU_0077-iU_0385. REQUEST NO. 10 10. Any and all documents provided to a party to this action, or other third parties regarding PLANET T, including but not limited to, sales reports, size charts, invoices, email correspondences and contracts. RESPONSE: iUniforms objects to Request No. 10 as overbroad, unlimited as to time or scope, and seeking information irrelevant to the subject matter of the above-styled action. iUniforms further objects to this request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms will produce responsive documents, if any, as they are kept in the usual course of business, identified by Bates ranges iU_0050 & iU_0077-iU_0385. REQUEST NO. 11 11. Any and all documents regarding complaints related to, evidence or reference iUNIFORMS’ services or products for FRANKLIN. RESPONSE: iUniforms objects to Request No. 11 as overbroad, unlimited as to time or scope, and seeking information irrelevant to the subject matter of the above-styled action. Additionally, producing all documents responsive to this Request would require the review of voluminous irrelevant materials containing confidential information such as customer names, phone numbers, e-mail addresses, and credit card information; such review and redaction would be overly burdensome, particularly in view of the irrelevance of such materials. iUniforms further objects to this request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms will produce non-privileged responsive documents as they are kept in the usual course of business, identified by Bates ranges iU_0050 & iU_0077—iU_0385.REQUEST NO. 12 12. All correspondence regarding or with mention of PLANET T, Maria Trotto, or Moshe Trotto. RESPONSE: iUniforms objects to Request No. 12 as overbroad, unlimited in time or scope, and seeking information irrelevant to the subject matter of the above-styled action, iUniforms further objects to this request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms will produce non-privileged responsive correspondence, as they are kept in the usual course of business, regarding or with mention of Planet T, identified by Bates Range iU_0050 & iU_0077i1U_0385. After a diligent search, iUniforms is currently unaware of any responsive, non-privileged correspondence regarding or with mention of Maria Trotto or Moshe Trotto in its possession, custody, or control. REQUEST NO. 13 13. Any and all documents related to, evidence or reference profit sharing between FRANKLIN and iUNIFORMS. RESPONSE: iUniforms objects to Request No. 13 as seeking documents irrelevant to the subject matter of the above-styled action. iUniforms further objects to this Request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms states that, after a diligent search, iUniforms is currently unaware of any responsive documents in its possession, custody, or control. REQUEST NO. 14 14. All documents (excluding attorney client communication and work product) iUNIFORMS relied upon in preparing its Motion to Dismiss. RESPONSE: iUniforms objects to this Request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms is currently unaware of any responsive documents in its possession, custody, or control. REQUEST NO. 15 15. All documents used or reviewed in anticipation of incorporating UNIFORMS. RESPONSE: iUniforms objects to Request No. 15 as seeking documents irrelevant to the subject matter of the above-styled action. iUniforms further objects to this Request to the extent it seeks privileged communications, including those protected by a joint 5defense agreement, or attorney work product. Subject to these objections, iUniforms will produce all non-privileged, responsive documents presently known to exist and within its possession, custody or control, identified by Bates range iU_0386-iU_0387. REQUEST NO. 16 16. Any and all documents or materials used to create i\UNIFORMS’ website. RESPONSE: iUniforms objects to Request No. 16 as seeking documents irrelevant to the subject matter of the above-styled action. iUniforms further objects to this Request to the extent it seeks privileged communications, including those protected by a joint defense agreement, or attorney work product. Subject to these objections, iUniforms will produce all non-privileged, responsive documents presently known to exist and within its possession, custody or control, identified by Bates range iU_0051-iU_0076. Respectfully Submitted, GREENBERG TRAURIG, P.A. Attorneys for Defendant iUniforms, Inc. 401 East Las Olas Boulevard Suite 2000 Fort Lauderdale, Florida 33301 Telephone: (954) 765-0500 Telefax: (954) 765-1477 By: __/s/Richard Rosengarten KENNETH A. HORKY Florida Bar Number 691194 HorkyK@gtlaw.com (€gtlaw.com gtlaw.com RICHARD ROSENGARTEN Florida Bar Number 0106169 RosengartenRich@gtlaw.com @gtlaw.comCERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing document was electronically filed in this action on June 28, 2016, through the Florida Courts E-filing Portal, and that the Portal was used as a means to serve the e-filed document upon all counsel and parties on the service list associated with this action. By: ___/s/Richard Rosengarten RICHARD ROSENGARTEN