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“+ FILED: BROWARD COUNTY, FL Howard C. Forman, CLERK 1/22/2016 11:12:55 AM.****
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT OF FLORIDA IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO. CACE-14-001087 (04)
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.
AGREED ORDER ON PLAINTIFF’S, PLANET T UNIFORMS, INC., REQUEST FOR
EXTENSION TO RESPOND TO DEFENDANT’S REQUEST FOR PRODUCTION AND
CONFIDENTIALITY ORDER
THIS CAUSE, having been agreed upon by Plaintiff, PLANET T UNIFORMS, INC.
(“Plaintiff”) and Defendants, FLORIDA CHARTER FOUNDATION, INC. D/B/A FRANKLIN
ACADEMY CHARTER SCHOOL (“FRANKLIN”), DISCOVERY SCHOOLS, INC.,
iUNIFORMS, INC., JON THOMAS ROGERS, AND SCOTT SZNITKEN, on Plaintiff's
Request for Extension to Respond to Defendant’s Request for Production and Request for a
Confidentiality Order, and the Court having considered the record, and being otherwise advised
in the premises, it is hereby,
ORDERED AND ADJUDGED as follows:
1. The Plaintiff's Request for Extension to Respond to FRANKLIN’s Request for
Production is hereby GRANTED and Plaintiff shall have 20 days from the date of
this Order to respond to said Request for Production.
Page | of 3CASE NO.: CACE-14-001087(04)
Agreed Order On Plaintiff's, Planet T Uniforms, Inc.’s
Request for Extension to Respond to Defendant’s Request for Production and Confidentiality Order
2. Plaintiff must produce all documents responsive to all requests in FRANKLIN’s
Request for Production that are not objected to, and if only a partial objection is
given, the balance of documents shall be produced on or before the above-referenced
due date.
3. Any and all documents or information produced by the parties in this action in the
course of discovery, which the producing party in good faith designates as
“confidential” (either by marking said documents and information “confidential” or
otherwise designating them as such), are protected by this Order.
If any Party objects to the designation of any material as confidential, the objecting
Party will make a good faith effort to first meet and confer with the designating Party
in an effort to resolve the dispute. If the designating and objecting parties are unable
to resolve the dispute, then they shall jointly apply to the Court for a determination of
whether the contested designation is valid in accordance with Florida law and the
standards set forth in this agreed order. A failure of a party to make a designation of
confidentiality, or challenge a designation of confidentiality when made, during the
course of discovery, shall not be a waiver of that party’s right to later assert that the
information actually is or is not confidential or entitled to the protection of this agreed
order. The contested information and documents shall retain their protected
confidential status pending resolution of the dispute.
Documents and information that are designated as confidential pursuant to this agreed
order are to be kept confidential and shall not be disclosed, disseminated or
distributed, and/or used except to prepare for, or during, a trial, court hearing,
deposition or settlement negotiation in this litigation. The only individuals other than
court reporters and courtroom personnel participating in this litigation who may
become privy to this information are lawyers specifically working on this litigation,
paralegals and secretaries working on this litigation, and expert witnesses retained
for this litigation. All persons who receive this information are bound by this Order
and will take all reasonably necessary steps to both prevent disclosure of this
information and limit access to this information. The parties shall require their own
Expert Witnesses receiving access to this information to agree to be bound by this
Order prior to receiving access to this information. Prior to permitting other
witnesses or potential witnesses access to this information, the parties shall present
to, and give, such persons a copy of this Order to read. A breach of this Order does
not render the Order void, allow for further breaches, or allow for the disclosure of
information disclosed in breach of this Order. This Order and obligation to keep this
information confidential survives and persists ad infinitum even when the above
captioned case is closed, regardless of how the case is closed. The parties shall make
reasonable efforts to destroy all such information within thirty-five days of
settlement, dismissal, verdict, or final judgment. If a party files an appeal, this
obligation to destroy such information shall run until thirty five days from the
entrance of the mandate, unless the appeal results in continued litigation.
Page 2 of 3CASE NO.: CACE-14-001087(04)
Agreed Order On Plaintiff's, Planet T Uniforms, Inc.'s
Request for Extension to Respond to Defendant's Request for Production and Confidentiality Order
DONE AND ORDERED in BROWARD County, Florida, Case No. CACE-14-
001087(04), this ___—s day of January, 2016, on the Agreed Order on Plaintiff's, Planet T
Uniforms, Inc.’s, Request for Extension to Respond to Defendant’s Request for Production and
Confidentiality Order.
SANDRA PERLMAN
CIRCUIT COURT JUDGE
Copies to:
David Di Pietro, Esq., david@ddpalaw.com
Ashley T. Steffen, Esq., ashley@ddpalaw.com
Christopher David, Esq., cdavid@fuerstlaw.com
Thomas David, Esq., tdavid@fuerstlaw.com
Kenneth A. Horky, Esq., horkyk@gtlaw.com
Richard Rosengarten, Esq., rosengartenrich@gtlaw.com
Page 3 of 3
uae Gi Electronically sianed by Judge Perlman, Sandra on 2016/01/22 09:10:18 EST.
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“+ FILED: BROWARD COUNTY, FL Howard C. Forman, CLERK 1/22/2016 11:12:55 AM.**** IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE-14-001087 (04) 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. AGREED ORDER ON PLAINTIFF’S, PLANET T UNIFORMS, INC., REQUEST FOR EXTENSION TO RESPOND TO DEFENDANT’S REQUEST FOR PRODUCTION AND CONFIDENTIALITY ORDER THIS CAUSE, having been agreed upon by Plaintiff, PLANET T UNIFORMS, INC. (“Plaintiff”) and Defendants, FLORIDA CHARTER FOUNDATION, INC. D/B/A FRANKLIN ACADEMY CHARTER SCHOOL (“FRANKLIN”), DISCOVERY SCHOOLS, INC., iUNIFORMS, INC., JON THOMAS ROGERS, AND SCOTT SZNITKEN, on Plaintiff's Request for Extension to Respond to Defendant’s Request for Production and Request for a Confidentiality Order, and the Court having considered the record, and being otherwise advised in the premises, it is hereby, ORDERED AND ADJUDGED as follows: 1. The Plaintiff's Request for Extension to Respond to FRANKLIN’s Request for Production is hereby GRANTED and Plaintiff shall have 20 days from the date of this Order to respond to said Request for Production. Page | of 3CASE NO.: CACE-14-001087(04) Agreed Order On Plaintiff's, Planet T Uniforms, Inc.’s Request for Extension to Respond to Defendant’s Request for Production and Confidentiality Order 2. Plaintiff must produce all documents responsive to all requests in FRANKLIN’s Request for Production that are not objected to, and if only a partial objection is given, the balance of documents shall be produced on or before the above-referenced due date. 3. Any and all documents or information produced by the parties in this action in the course of discovery, which the producing party in good faith designates as “confidential” (either by marking said documents and information “confidential” or otherwise designating them as such), are protected by this Order. If any Party objects to the designation of any material as confidential, the objecting Party will make a good faith effort to first meet and confer with the designating Party in an effort to resolve the dispute. If the designating and objecting parties are unable to resolve the dispute, then they shall jointly apply to the Court for a determination of whether the contested designation is valid in accordance with Florida law and the standards set forth in this agreed order. A failure of a party to make a designation of confidentiality, or challenge a designation of confidentiality when made, during the course of discovery, shall not be a waiver of that party’s right to later assert that the information actually is or is not confidential or entitled to the protection of this agreed order. The contested information and documents shall retain their protected confidential status pending resolution of the dispute. Documents and information that are designated as confidential pursuant to this agreed order are to be kept confidential and shall not be disclosed, disseminated or distributed, and/or used except to prepare for, or during, a trial, court hearing, deposition or settlement negotiation in this litigation. The only individuals other than court reporters and courtroom personnel participating in this litigation who may become privy to this information are lawyers specifically working on this litigation, paralegals and secretaries working on this litigation, and expert witnesses retained for this litigation. All persons who receive this information are bound by this Order and will take all reasonably necessary steps to both prevent disclosure of this information and limit access to this information. The parties shall require their own Expert Witnesses receiving access to this information to agree to be bound by this Order prior to receiving access to this information. Prior to permitting other witnesses or potential witnesses access to this information, the parties shall present to, and give, such persons a copy of this Order to read. A breach of this Order does not render the Order void, allow for further breaches, or allow for the disclosure of information disclosed in breach of this Order. This Order and obligation to keep this information confidential survives and persists ad infinitum even when the above captioned case is closed, regardless of how the case is closed. The parties shall make reasonable efforts to destroy all such information within thirty-five days of settlement, dismissal, verdict, or final judgment. If a party files an appeal, this obligation to destroy such information shall run until thirty five days from the entrance of the mandate, unless the appeal results in continued litigation. Page 2 of 3CASE NO.: CACE-14-001087(04) Agreed Order On Plaintiff's, Planet T Uniforms, Inc.'s Request for Extension to Respond to Defendant's Request for Production and Confidentiality Order DONE AND ORDERED in BROWARD County, Florida, Case No. CACE-14- 001087(04), this ___—s day of January, 2016, on the Agreed Order on Plaintiff's, Planet T Uniforms, Inc.’s, Request for Extension to Respond to Defendant’s Request for Production and Confidentiality Order. SANDRA PERLMAN CIRCUIT COURT JUDGE Copies to: David Di Pietro, Esq., david@ddpalaw.com Ashley T. Steffen, Esq., ashley@ddpalaw.com Christopher David, Esq., cdavid@fuerstlaw.com Thomas David, Esq., tdavid@fuerstlaw.com Kenneth A. Horky, Esq., horkyk@gtlaw.com Richard Rosengarten, Esq., rosengartenrich@gtlaw.com Page 3 of 3 uae Gi Electronically sianed by Judge Perlman, Sandra on 2016/01/22 09:10:18 EST.