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Filing # 40412864 E-Filed 04/18/2016 06:14:11 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.,
v.
Plaintiff,
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 REQUEST FOR PRODUCTION TO
DEFENDANT
Plaintiff, PLANET T UNIFORMS, INC., (“PLANET T”), by and through undersigned
counsel, hereby propounds its First Request for Production on Defendant, iUNIFORMS, INC.
(“iUNIFORMS”).
1.
Any and all contracts between you and FLORIDA CHARTER FOUNDATION, INC.
/b/a FRANKLIN ACADEMY CHARTER (“FRANKLIN”).
Any and all contracts between you and FLORIDA CHARTER FOUNDATION, INC.
. Any and all correspondence between you and FRANKLIN.
Any and all documents between you and FRANKLIN regarding services provided to
FRANKLIN for the 2012-2013 school year.
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.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/18/2016 6:14:11 PM.****10.
12.
13.
14.
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.
Any and all documents received from a party to this action, or other third parties
which has PLANET T’s name on it.
Any and all documents provided to a party to this action, or other third parties which
has PLANET T’s name on it.
Any and all documents received from 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.
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.
. Any and all documents regarding complaints related to, evidence or reference
iUNIFORMS' services or products for FRANKLIN.
All correpsondenece regarding or with mention of PLANET T, Maria Trotto, or
Moshe Trotto.
Any and all documents related to, evidence or reference profit sharing between
FRANKLIN and iUNIFORMS.
All documents (excluding attorney client communication and work product)
iUNIFORMS relied upon in preparing its Motion to Dismiss.
. All documents used or reviewed in anticipation of incorporating iUNIFORMS.
. Any and all documents or materials used to create UNIFORMS’ website.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 April 18, 2016.
DAVID DI PIETRO & ASSOCIATES, P.A.
The Law Offices of David Di Pietro, P.A.
Tower 101
101 NE 3™ Avenue, Suite 1410
Fort Lauderdale, FL 33301
Primary: service@ddpalaw.com
Telephone: (954) 712-3070
Facsimile: (954) 337-3824
/s/ Ashley T. Steffen
DAVID DI PIETRO, ESQ.
Florida Bar No.: 10370
david@ddpawlaw.com
ASHLEY T. STEFFEN, ESQ.
Florida Bar No.: 111238
ashley@ddpawlaw.com
SERVICE LIST
Christopher M. David, Esq.
Fuerst Ittleman David & Joseph, PL
1001 Brickell Bay Drive, 32"° Floor
Miami, Florida 33131
Emails: ¢
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
jJavid@fuerstlaw.com; tdavid(ajfucrsuaw.com;
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Filing # 40412864 E-Filed 04/18/2016 06:14:11 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., v. Plaintiff, 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 REQUEST FOR PRODUCTION TO DEFENDANT Plaintiff, PLANET T UNIFORMS, INC., (“PLANET T”), by and through undersigned counsel, hereby propounds its First Request for Production on Defendant, iUNIFORMS, INC. (“iUNIFORMS”). 1. Any and all contracts between you and FLORIDA CHARTER FOUNDATION, INC. /b/a FRANKLIN ACADEMY CHARTER (“FRANKLIN”). Any and all contracts between you and FLORIDA CHARTER FOUNDATION, INC. . Any and all correspondence between you and FRANKLIN. Any and all documents between you and FRANKLIN regarding services provided to FRANKLIN for the 2012-2013 school year. 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. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/18/2016 6:14:11 PM.****10. 12. 13. 14. 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. Any and all documents received from a party to this action, or other third parties which has PLANET T’s name on it. Any and all documents provided to a party to this action, or other third parties which has PLANET T’s name on it. Any and all documents received from 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. 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. . Any and all documents regarding complaints related to, evidence or reference iUNIFORMS' services or products for FRANKLIN. All correpsondenece regarding or with mention of PLANET T, Maria Trotto, or Moshe Trotto. Any and all documents related to, evidence or reference profit sharing between FRANKLIN and iUNIFORMS. All documents (excluding attorney client communication and work product) iUNIFORMS relied upon in preparing its Motion to Dismiss. . All documents used or reviewed in anticipation of incorporating iUNIFORMS. . Any and all documents or materials used to create UNIFORMS’ website.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 April 18, 2016. DAVID DI PIETRO & ASSOCIATES, P.A. The Law Offices of David Di Pietro, P.A. Tower 101 101 NE 3™ Avenue, Suite 1410 Fort Lauderdale, FL 33301 Primary: service@ddpalaw.com Telephone: (954) 712-3070 Facsimile: (954) 337-3824 /s/ Ashley T. Steffen DAVID DI PIETRO, ESQ. Florida Bar No.: 10370 david@ddpawlaw.com ASHLEY T. STEFFEN, ESQ. Florida Bar No.: 111238 ashley@ddpawlaw.com SERVICE LIST Christopher M. David, Esq. Fuerst Ittleman David & Joseph, PL 1001 Brickell Bay Drive, 32"° Floor Miami, Florida 33131 Emails: ¢ 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 jJavid@fuerstlaw.com; tdavid(ajfucrsuaw.com;