Preview
Filing # 30769921 E-Filed 08/12/2015 11:37:35 AM
IN THE CIRCUIT COURT OF THE 17'4 JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE-14-001087 (04)
PLANET T UNIFORMS, INC.,
Plaintiff,
vz.
FLORIDA CHARTER FOUNDATION, INC.,
D/B/A FRANKLIN ACADEMY CHARTER
SCHOOL,
Defendant.
FLORIDA CHARTER FOUNDATION, INC.,
D/B/A FRANKLIN ACADEMY CHARTER
SCHOOL,
Counter-Plaintiff,
v.
PLANET T UNIFORMS, INC.,
Counter-Defendant.
/
REQUEST FOR PRODUCTION TO PLAINTIFF
The Defendant, Florida Charter Foundation, Inc. D/B/A Franklin Academy
Charter School (“FCF”), by and through undersigned counsel, pursuant to the Florida
Rules of Civil Procedure hereby files and serves its Request for Production to the Plaintiff
and requests that the following documents be produced in accordance with Rule 1.350 as
follows:
1- Scope and Procedure
1. This Request for Production is intended to cover all documents in the possession,
custody or control of the Plaintiff or any of its agents, representatives, servants, employees,
accountants or attorneys, wherever those documents might be located.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/12/2015 11:37:34 AM.****CASE NO.: CACE-14-001087 (04)
2. Each request should be read so as not to include documents or things subject to an
evidentiary privilege or immunity from discovery if necessary to permit the production of
documents or things otherwise responsive to the request. To the extent that this request calls for
the production of documents or things subject to a privilege or immunity from discovery, the
written response to this request should so indicate, but Plaintiff is directed to produce the balance
of the documents or things not subject to a claim of privilege which fall within the scope of the
request.
3. The documents called for by this Request, unless otherwise specified (as, for
example, by specification of another period of time or by use of the word “ever” or the phrase “at
any time”), and without regard to the verbal tense use in the request, are those containing
information from October 1, 2010 to the present.
4. If a document was but is no longer in Plaintiffs possession, custody or control,
please state the disposition of the document, by whom it was disposed, the approximate date or
dates on which the disposition was made and the reason for the disposition.
5. The singular shall include the plural and vice versa; the terms “and” or “or” shall
be both conjunctive and disjunctive; and the term “including” mean “including without limitation”.
Il. Definitions
As used below, the following words shall have the meanings indicated:
lL. “Plaintiff”, “You” or “Your” shall mean Planet T Uniforms, Inc. and any directors,
officers, employees, agents, representatives or other persons acting, or purporting to act, its behalf.
2. “Document” has the full extent of its meaning as provided in the Florida Rules of
Civil Procedure, and shall mean any writing and any other tangible thing containing written or
graphic matter, whether printed, recorded, reproduced by any process, or written or produced by
hand, including but not limited to the original and any non-identical copy, including the following:
letters, reports, agreements (including drafts, proposals and any and all exhibits thereto),
communications, including inter-company communications, correspondence, telegrams, teletype
messages, memoranda, summaries, recordings, records of personal conversations, diaries,
forecasts, photographs, tape records, models, statistical statements, graphics, laboratory and
engineering reports and notebooks, charts, plans, drawings, minutes, records of conferences,
agendas, expressions or statements of policy, lists of persons attending meetings or conferences,
reports, summaries of interviews, reports and/or summaries or investigations, inspections, opinions
or reports of consultants, brochures, pamphlets, advertisements, circular, trade letters, press
releases, drafts of any documents and revisions of drafts of any documents, tabulations, charts,
books of account, ledgers, invoices, financial statements, purchase orders, receipts, canceled
checks and things similar to the foregoing, however denominated by Plaintiff or its agents. The
term “document” shall include data stored, maintained or organized electronically, magnetically
or through the use of computer equipment, translated, if necessary, by you into reasonably usable
form,CASE NO.: CACE-14-001087 (04)
3. “Relating to” shall mean referring to, evidencing, pertaining to, consisting of,
reflecting, concerning, or in any way logically or factually connected with the matter discussed or
to which reference is made.
4. “Agent” shall mean: any agent, employee, officer, director, attorney, independent
contractor or any other person acting at the direction of or on behalf of another.
5. “Date” shall mean the exact date, month and year, if ascertainable or, if not, the
best approximation of the date (based upon relationship with other events).
6. “Person” shall mean any individual, corporation, proprietorship, partnership, trust,
association or any other entity.
7. The words “pertain to” or “pertaining to” mean: relates to, refers to, contains,
concerns, describes, embodies, mentions, constitutes, constituting, supports, corroborates,
demonstrates, proves, evidences, shows, refutes, disputes, rebuts, controverts or contradicts.
II. Instructions On Documents As To
Which A Claim Of Privilege Is Asserted
As to each document requested which you object to producing on the basis of any
evidentiary privilege or immunity from discovery, please provide the following information:
1. The basis for the privilege being invoked;
2. The date of the document;
3. The title of the document (if any);
4. The name of the person(s) authoring the document;
5 The name of the person(s) to whom the document and/or any copies thereof were
given or transmitted;
6. The present location and custodian of the document, or any copies thereof: and,
7. The general subject matter dealt with in the document with reasonable specificity.
SPECIFIC DOCUMENT REQUESTS
1. A complete copy of the General Ledger (in its native electronic and physical
format) of Planet T Uniforms, Inc. for years 2010, 2011, 2012, 2013 and 2014.
2. A complete copy of the Income Statement (in its native electronic and physical
format) of Planet T Uniforms, Inc. for years 2010, 2011, 2012, 2013 and 2014.
3. A complete copy of the Balance Sheet (in its native electronic and physical format)
of Planet T Uniforms, Inc. for years 2010, 2011, 2012, 2013 and 2014,CASE NO.: CACE-14-001087 (04)
4, All documents, correspondence, letters, e-mails or any other method of
communication between anyone purporting to act on behalf of Plaintiff and customer of the
Plaintiff related to the provision by the Plaintiff of school uniforms or clothing.
5. All documents, correspondence, letters, e-mails or any other method of
communication which identifies the Plaintiffs customers during the years 2010, 2011, 2012 and
2013.
6. All documents, correspondence, letters, e-mails or any other method of
communication which identifies all of contracts between the Plaintiff and any of its customers
during the years 2010, 2011, 2012 and 2013.
7. All documents, correspondence, letters, e-mails or any other method of
communication related to any and all contracts or proposals between anyone purporting to act on
behalf of Plaintiff and any other person or entity related to the provision by the Plaintiff of school
uniforms or clothing.
8. All correspondence, letters, e-mails or any other method of communication
between the Plaintiff, or anyone purporting to act on its behalf, and any of the Defendants identified
in the Amended Complaint.
9. All correspondence, letters, e-mails or any other method of communication
between anyone purporting to act on behalf of Plaintiff and person or entity related to the purchase
by Plaintiff of school uniforms.
10. All correspondence, letters, e-mails or any other method of communication
between anyone purporting to act on behalf of Plaintiff and person or entity related to the purchase
by Plaintiff of any goods or school uniforms as alleged in paragraph 30 of the Amended Complaint.
ll. All documents, correspondence, letters, e-mails or any other method of
communication between anyone purporting to act on behalf of Plaintiff and person or entity related
4CASE NO.: CACE-14-001087 (04)
to the “inventory specifically allotted to Franklin” as alleged in paragraph 40 and 42 of the
Amended Complaint.
12. All documents, correspondence, letters, e-mails or any other method of
communication between anyone purporting to act on behalf of Plaintiff and person or entity related
to the “specially manufactured uniforms” currently in Plaintiffs inventory as alleged in paragraph
41 of the Amended Complaint.
13. All documents, correspondence, letters, e-mails or any other method of
communication between anyone and the Plaintiff related to the “complaints” alleged in paragraph
44 of the Amended Complaint.
14. All documents, correspondence, letters, e-mails or any other method of
communication related to or supporting the allegations contained in paragraph 46, including all
sub-parts, of the Amended Complaint.
15. All documents, correspondence, letters, e-mails or any other method of
communication related to or supporting the allegations contained in paragraph 47 of the Amended
Complaint.
16. All documents, correspondence, letters, e-mails or any other method of
communication related to or supporting the allegations contained in paragraph 54 of the Amended
Complaint.
17. All documents, correspondence, letters, e-mails or any other method of
communication related to or supporting the allegations contained in paragraph 55 of the Amended
Complaint.
18. All documents, correspondence, letters, e-mails or any other method of
communication related to or supporting the allegations contained in paragraph 56 of the Amended
Complaint.CASE NO.: CACE-14-001087 (04)
19, All documents, correspondence, letters, e-mails or any other method of
communication related to or supporting the allegations contained in paragraph 57 of the Amended
Complaint.
20. All documents, correspondence, letters, e-mails or any other method of
communication related to or supporting the allegations contained in paragraph 58 of the Amended
Complaint.
21, All documents, correspondence, letters, e-mails or any other method of
communication related to or identifying the “proprietary information” alleged in paragraph 60 of
the Amended Complaint.
22 All documents, correspondence, letters, e-mails or any other method of
communication related to or identifying the “oral agreement” alleged in paragraphs 92 and 93 of
the Amended Complaint.
23. All documents, correspondence, letters, e-mails or any other method of
communication related to or identifying the “specially manufactured goods” which were allegedly
agreed to be supplied by the Plaintiff to Defendant Florida Charter Foundation, Inc. as alleged in
paragraphs 96 and 97 of the Amended Complaint.
24. All documents, correspondence, letters, e-mails or any other method of
communication related to or identifying the “oral promise” whereby Defendant Florida Charter
Foundation promised to order specially manufactured goods from the Plaintiff as alleged in
paragraphs 100 through 103 of the Amended Complaint.
25 All documents, correspondence, letters, e-mails or any other method of
communication related to or identifying the “trade secrets” alleged in paragraph 177 of the
Amended Complaint.CASE NO.: CACE-14-001087 (04)
26. All documents, correspondence, letters, e-mails or any other method of
communication related to or identifying the policies and/or procedures utilized or followed by the
Plaintiff to protect or safeguard the “trade secrets” referenced in the Amended Complaint.
27. All documents, correspondence, letters, e-mails or any other method of
communication related to or identifying the “improper means” by which Defendant Florida
Charter Foundation, Inc. is alleged to have acquired the Plaintiff’s “trade secrets” as alleged in
paragraph 179 of the Amended Complaint.
28. All documents, correspondence, letters, e-mails or any other method of
communication related to or supporting the claim that Defendant Florida Charter Foundation, Inc.
“misappropriated [the Plaintiff's] trade secrets” as alleged in paragraph 180 of the Amended
Complaint.
29. A complete copy of the corporate book of Planet T Uniforms, Inc.
30. A complete copy of the By-Laws of Planet T Uniforms, Inc. (including any
revisions or amendments thereto).
31. A complete copy of the Articles of Incorporation of Planet T Uniforms, Inc.
(including any revisions or amendments thereto).
32. Copies of all Form K-1 issued by Planet T Uniforms, Inc. to any person or entity.
33. Complete copies of all tax returns filed by Planet T Uniforms, Inc. with the United
States Treasury Internal Revenue Service for the years 2009 through 2014.
34. All waivers of notice of meeting issued in connection with any meeting of
shareholders of Planet T Uniforms, Inc.
35. A complete copy of each and every document related to corporate structure or
corporate governance of Planet T Uniforms, Inc.
36. | Acomplete copy of all share certificates issued by Planet T Uniforms, Inc.
7CASE NO.: CACE-14-001087 (04)
37. Complete copies of all form 1120S (including any and all amendments thereto)
filed by Planet T Uniforms, Inc. with the Internal Revenue Service for the years 2009 through
2014.
38. Any and all documents related to any and all capital contributions paid by any
person or entity to Planet T Uniforms, Inc.
39. Any and all documents related to any compensation paid to any officer or director
of Planet T Uniforms, Inc.
40. Any and all documents related to any payment representing any profit
distribution(s) paid to any person by Planet T Uniforms, Inc:
4l All documents or tangible information referencing, related to, or establishing any
amount of damages alleged to have been incurred by the Plaintiff as alleged in Amended
Complaint.
42. All documents or tangible information referencing, related to, or establishing any
amount of damages alleged to have been incurred by the Plaintiff as alleged in Count I of the
Amended Complaint.
43, All documents or tangible information referencing, related to, or establishing any
amount of damages alleged to have been incurred by the Plaintiff as alleged in Count V of the
Amended Complaint.
44. All documents or tangible information referencing, related to, or establishing any
amount of damages alleged to have been incurred by the Plaintiff as alleged in Count VI of the
Amended Complaint.
45. All documents or tangible information referencing, related to, or establishing any
amount of damages alleged to have been incurred by the Plaintiff as alleged in Count XXII of the
Amended Complaint.CASE NO.: CACE-14-001087 (04)
46. Copies of all checks or wire transfers or other evidence of the transfer of monies
representing any payment representing a “revenue contribution” paid by the Plaintiff to Defendant
Florida Charter Foundation, Inc. during the years 2010, 2011, 2012 and/or 2013.
47, All documents or tangible information related to, representing, identifying or
setting forth the revenue realized by Plaintiff in connection with any item of clothing bearing the
Franklin Academy logo for the years 2010, 2011, 2012 and/or 2013.
Respectfully submitted,
FUERST ITTLEMAN DAVID & JOSEPH, PL
1001 Brickell Bay Drive
32na Floor
Miami, Florida 33131
Tel. (305) 350-5690
Fax (305) 371-8989
E-mail: Cdavid@fuerstlaw.com
E-mail: Tdavidé tlaw.com
Secondary: grodriguez@fuerstlaw.com
Counsel for Florida Charter Foundation, Inc.
By: /s/ CHRISTOPHER M. DAVID
Florida Bar No. 985163
Thomas M. David
Florida Bar No. 20846
CERTIFICATE OF SERVICE
I certify that on August 12, 2015, 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.
/s/ Christopher M. David
CHRISTOPHER M. DAVID
Florida Bar No. 985163
Preview
Filing # 30769921 E-Filed 08/12/2015 11:37:35 AM IN THE CIRCUIT COURT OF THE 17'4 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-14-001087 (04) PLANET T UNIFORMS, INC., Plaintiff, vz. FLORIDA CHARTER FOUNDATION, INC., D/B/A FRANKLIN ACADEMY CHARTER SCHOOL, Defendant. FLORIDA CHARTER FOUNDATION, INC., D/B/A FRANKLIN ACADEMY CHARTER SCHOOL, Counter-Plaintiff, v. PLANET T UNIFORMS, INC., Counter-Defendant. / REQUEST FOR PRODUCTION TO PLAINTIFF The Defendant, Florida Charter Foundation, Inc. D/B/A Franklin Academy Charter School (“FCF”), by and through undersigned counsel, pursuant to the Florida Rules of Civil Procedure hereby files and serves its Request for Production to the Plaintiff and requests that the following documents be produced in accordance with Rule 1.350 as follows: 1- Scope and Procedure 1. This Request for Production is intended to cover all documents in the possession, custody or control of the Plaintiff or any of its agents, representatives, servants, employees, accountants or attorneys, wherever those documents might be located. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/12/2015 11:37:34 AM.****CASE NO.: CACE-14-001087 (04) 2. Each request should be read so as not to include documents or things subject to an evidentiary privilege or immunity from discovery if necessary to permit the production of documents or things otherwise responsive to the request. To the extent that this request calls for the production of documents or things subject to a privilege or immunity from discovery, the written response to this request should so indicate, but Plaintiff is directed to produce the balance of the documents or things not subject to a claim of privilege which fall within the scope of the request. 3. The documents called for by this Request, unless otherwise specified (as, for example, by specification of another period of time or by use of the word “ever” or the phrase “at any time”), and without regard to the verbal tense use in the request, are those containing information from October 1, 2010 to the present. 4. If a document was but is no longer in Plaintiffs possession, custody or control, please state the disposition of the document, by whom it was disposed, the approximate date or dates on which the disposition was made and the reason for the disposition. 5. The singular shall include the plural and vice versa; the terms “and” or “or” shall be both conjunctive and disjunctive; and the term “including” mean “including without limitation”. Il. Definitions As used below, the following words shall have the meanings indicated: lL. “Plaintiff”, “You” or “Your” shall mean Planet T Uniforms, Inc. and any directors, officers, employees, agents, representatives or other persons acting, or purporting to act, its behalf. 2. “Document” has the full extent of its meaning as provided in the Florida Rules of Civil Procedure, and shall mean any writing and any other tangible thing containing written or graphic matter, whether printed, recorded, reproduced by any process, or written or produced by hand, including but not limited to the original and any non-identical copy, including the following: letters, reports, agreements (including drafts, proposals and any and all exhibits thereto), communications, including inter-company communications, correspondence, telegrams, teletype messages, memoranda, summaries, recordings, records of personal conversations, diaries, forecasts, photographs, tape records, models, statistical statements, graphics, laboratory and engineering reports and notebooks, charts, plans, drawings, minutes, records of conferences, agendas, expressions or statements of policy, lists of persons attending meetings or conferences, reports, summaries of interviews, reports and/or summaries or investigations, inspections, opinions or reports of consultants, brochures, pamphlets, advertisements, circular, trade letters, press releases, drafts of any documents and revisions of drafts of any documents, tabulations, charts, books of account, ledgers, invoices, financial statements, purchase orders, receipts, canceled checks and things similar to the foregoing, however denominated by Plaintiff or its agents. The term “document” shall include data stored, maintained or organized electronically, magnetically or through the use of computer equipment, translated, if necessary, by you into reasonably usable form,CASE NO.: CACE-14-001087 (04) 3. “Relating to” shall mean referring to, evidencing, pertaining to, consisting of, reflecting, concerning, or in any way logically or factually connected with the matter discussed or to which reference is made. 4. “Agent” shall mean: any agent, employee, officer, director, attorney, independent contractor or any other person acting at the direction of or on behalf of another. 5. “Date” shall mean the exact date, month and year, if ascertainable or, if not, the best approximation of the date (based upon relationship with other events). 6. “Person” shall mean any individual, corporation, proprietorship, partnership, trust, association or any other entity. 7. The words “pertain to” or “pertaining to” mean: relates to, refers to, contains, concerns, describes, embodies, mentions, constitutes, constituting, supports, corroborates, demonstrates, proves, evidences, shows, refutes, disputes, rebuts, controverts or contradicts. II. Instructions On Documents As To Which A Claim Of Privilege Is Asserted As to each document requested which you object to producing on the basis of any evidentiary privilege or immunity from discovery, please provide the following information: 1. The basis for the privilege being invoked; 2. The date of the document; 3. The title of the document (if any); 4. The name of the person(s) authoring the document; 5 The name of the person(s) to whom the document and/or any copies thereof were given or transmitted; 6. The present location and custodian of the document, or any copies thereof: and, 7. The general subject matter dealt with in the document with reasonable specificity. SPECIFIC DOCUMENT REQUESTS 1. A complete copy of the General Ledger (in its native electronic and physical format) of Planet T Uniforms, Inc. for years 2010, 2011, 2012, 2013 and 2014. 2. A complete copy of the Income Statement (in its native electronic and physical format) of Planet T Uniforms, Inc. for years 2010, 2011, 2012, 2013 and 2014. 3. A complete copy of the Balance Sheet (in its native electronic and physical format) of Planet T Uniforms, Inc. for years 2010, 2011, 2012, 2013 and 2014,CASE NO.: CACE-14-001087 (04) 4, All documents, correspondence, letters, e-mails or any other method of communication between anyone purporting to act on behalf of Plaintiff and customer of the Plaintiff related to the provision by the Plaintiff of school uniforms or clothing. 5. All documents, correspondence, letters, e-mails or any other method of communication which identifies the Plaintiffs customers during the years 2010, 2011, 2012 and 2013. 6. All documents, correspondence, letters, e-mails or any other method of communication which identifies all of contracts between the Plaintiff and any of its customers during the years 2010, 2011, 2012 and 2013. 7. All documents, correspondence, letters, e-mails or any other method of communication related to any and all contracts or proposals between anyone purporting to act on behalf of Plaintiff and any other person or entity related to the provision by the Plaintiff of school uniforms or clothing. 8. All correspondence, letters, e-mails or any other method of communication between the Plaintiff, or anyone purporting to act on its behalf, and any of the Defendants identified in the Amended Complaint. 9. All correspondence, letters, e-mails or any other method of communication between anyone purporting to act on behalf of Plaintiff and person or entity related to the purchase by Plaintiff of school uniforms. 10. All correspondence, letters, e-mails or any other method of communication between anyone purporting to act on behalf of Plaintiff and person or entity related to the purchase by Plaintiff of any goods or school uniforms as alleged in paragraph 30 of the Amended Complaint. ll. All documents, correspondence, letters, e-mails or any other method of communication between anyone purporting to act on behalf of Plaintiff and person or entity related 4CASE NO.: CACE-14-001087 (04) to the “inventory specifically allotted to Franklin” as alleged in paragraph 40 and 42 of the Amended Complaint. 12. All documents, correspondence, letters, e-mails or any other method of communication between anyone purporting to act on behalf of Plaintiff and person or entity related to the “specially manufactured uniforms” currently in Plaintiffs inventory as alleged in paragraph 41 of the Amended Complaint. 13. All documents, correspondence, letters, e-mails or any other method of communication between anyone and the Plaintiff related to the “complaints” alleged in paragraph 44 of the Amended Complaint. 14. All documents, correspondence, letters, e-mails or any other method of communication related to or supporting the allegations contained in paragraph 46, including all sub-parts, of the Amended Complaint. 15. All documents, correspondence, letters, e-mails or any other method of communication related to or supporting the allegations contained in paragraph 47 of the Amended Complaint. 16. All documents, correspondence, letters, e-mails or any other method of communication related to or supporting the allegations contained in paragraph 54 of the Amended Complaint. 17. All documents, correspondence, letters, e-mails or any other method of communication related to or supporting the allegations contained in paragraph 55 of the Amended Complaint. 18. All documents, correspondence, letters, e-mails or any other method of communication related to or supporting the allegations contained in paragraph 56 of the Amended Complaint.CASE NO.: CACE-14-001087 (04) 19, All documents, correspondence, letters, e-mails or any other method of communication related to or supporting the allegations contained in paragraph 57 of the Amended Complaint. 20. All documents, correspondence, letters, e-mails or any other method of communication related to or supporting the allegations contained in paragraph 58 of the Amended Complaint. 21, All documents, correspondence, letters, e-mails or any other method of communication related to or identifying the “proprietary information” alleged in paragraph 60 of the Amended Complaint. 22 All documents, correspondence, letters, e-mails or any other method of communication related to or identifying the “oral agreement” alleged in paragraphs 92 and 93 of the Amended Complaint. 23. All documents, correspondence, letters, e-mails or any other method of communication related to or identifying the “specially manufactured goods” which were allegedly agreed to be supplied by the Plaintiff to Defendant Florida Charter Foundation, Inc. as alleged in paragraphs 96 and 97 of the Amended Complaint. 24. All documents, correspondence, letters, e-mails or any other method of communication related to or identifying the “oral promise” whereby Defendant Florida Charter Foundation promised to order specially manufactured goods from the Plaintiff as alleged in paragraphs 100 through 103 of the Amended Complaint. 25 All documents, correspondence, letters, e-mails or any other method of communication related to or identifying the “trade secrets” alleged in paragraph 177 of the Amended Complaint.CASE NO.: CACE-14-001087 (04) 26. All documents, correspondence, letters, e-mails or any other method of communication related to or identifying the policies and/or procedures utilized or followed by the Plaintiff to protect or safeguard the “trade secrets” referenced in the Amended Complaint. 27. All documents, correspondence, letters, e-mails or any other method of communication related to or identifying the “improper means” by which Defendant Florida Charter Foundation, Inc. is alleged to have acquired the Plaintiff’s “trade secrets” as alleged in paragraph 179 of the Amended Complaint. 28. All documents, correspondence, letters, e-mails or any other method of communication related to or supporting the claim that Defendant Florida Charter Foundation, Inc. “misappropriated [the Plaintiff's] trade secrets” as alleged in paragraph 180 of the Amended Complaint. 29. A complete copy of the corporate book of Planet T Uniforms, Inc. 30. A complete copy of the By-Laws of Planet T Uniforms, Inc. (including any revisions or amendments thereto). 31. A complete copy of the Articles of Incorporation of Planet T Uniforms, Inc. (including any revisions or amendments thereto). 32. Copies of all Form K-1 issued by Planet T Uniforms, Inc. to any person or entity. 33. Complete copies of all tax returns filed by Planet T Uniforms, Inc. with the United States Treasury Internal Revenue Service for the years 2009 through 2014. 34. All waivers of notice of meeting issued in connection with any meeting of shareholders of Planet T Uniforms, Inc. 35. A complete copy of each and every document related to corporate structure or corporate governance of Planet T Uniforms, Inc. 36. | Acomplete copy of all share certificates issued by Planet T Uniforms, Inc. 7CASE NO.: CACE-14-001087 (04) 37. Complete copies of all form 1120S (including any and all amendments thereto) filed by Planet T Uniforms, Inc. with the Internal Revenue Service for the years 2009 through 2014. 38. Any and all documents related to any and all capital contributions paid by any person or entity to Planet T Uniforms, Inc. 39. Any and all documents related to any compensation paid to any officer or director of Planet T Uniforms, Inc. 40. Any and all documents related to any payment representing any profit distribution(s) paid to any person by Planet T Uniforms, Inc: 4l All documents or tangible information referencing, related to, or establishing any amount of damages alleged to have been incurred by the Plaintiff as alleged in Amended Complaint. 42. All documents or tangible information referencing, related to, or establishing any amount of damages alleged to have been incurred by the Plaintiff as alleged in Count I of the Amended Complaint. 43, All documents or tangible information referencing, related to, or establishing any amount of damages alleged to have been incurred by the Plaintiff as alleged in Count V of the Amended Complaint. 44. All documents or tangible information referencing, related to, or establishing any amount of damages alleged to have been incurred by the Plaintiff as alleged in Count VI of the Amended Complaint. 45. All documents or tangible information referencing, related to, or establishing any amount of damages alleged to have been incurred by the Plaintiff as alleged in Count XXII of the Amended Complaint.CASE NO.: CACE-14-001087 (04) 46. Copies of all checks or wire transfers or other evidence of the transfer of monies representing any payment representing a “revenue contribution” paid by the Plaintiff to Defendant Florida Charter Foundation, Inc. during the years 2010, 2011, 2012 and/or 2013. 47, All documents or tangible information related to, representing, identifying or setting forth the revenue realized by Plaintiff in connection with any item of clothing bearing the Franklin Academy logo for the years 2010, 2011, 2012 and/or 2013. Respectfully submitted, FUERST ITTLEMAN DAVID & JOSEPH, PL 1001 Brickell Bay Drive 32na Floor Miami, Florida 33131 Tel. (305) 350-5690 Fax (305) 371-8989 E-mail: Cdavid@fuerstlaw.com E-mail: Tdavidé tlaw.com Secondary: grodriguez@fuerstlaw.com Counsel for Florida Charter Foundation, Inc. By: /s/ CHRISTOPHER M. DAVID Florida Bar No. 985163 Thomas M. David Florida Bar No. 20846 CERTIFICATE OF SERVICE I certify that on August 12, 2015, 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. /s/ Christopher M. David CHRISTOPHER M. DAVID Florida Bar No. 985163