On January 16, 2014 a
Party Discovery
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.
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Filing # 17668828 Electronically Filed 08/29/2014 09:59:23 AM
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,
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.
/
DEFENDANT'S RESPONSE TO PLAINTIFF’S
FIRST REQUEST FOR ADMISSIONS
Defendant FLORIDA CHARTER FOUNDATION, INC., D/B/A FRANKLIN
ACADEMY CHARTER SCHOOL, (hereinafter “Defendant”) by and through
undersigned counsel, and pursuant to Rule 1.380 of the Florida Rules of Civil Procedure
hereby respond to the Plaintiff's First Request for Admissions dated July 31, 2014 as
follows:
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/29/2014 9:59:22 AM.****1.
CASE NO.: CACE-14-001087 (04)
The Defendant is unable to admit or deny the subject request. The
Defendant engaged in good faith negotiations with the Plaintiff. Those negotiations did
not result in a written contract.
2.
Admitted.
Denied.
Denied.
Denied.
Denied.
Admitted. Defendant received complaints from student's parents related
to Planet T as well.
8.
9.
10.
11.
12.
13.
14.
15.
Denied.
Denied.
“FRANKLIN” does not sell uniforms. Denied.
“FRANKLIN” does not sell uniforms. Denied.
“FRANKLIN” does not sell uniforms. Denied.
“FRANKLIN” does not sell uniforms. Denied.
Denied.
The Defendant is unable to admit or deny request number 15 as phrased.
The Defendant believes that its first contact with iUniforms was in the first quarter of
2013. The Defendant is unable to confirm whether its first contact with iUniforms
related to iUniforms being an “exclusive” uniform vendor was prior to February 1,
2013.CASE NO.: CACE-14-001087 (04)
Respectfully submitted,
FUERST ITTLEMAN DAVID & JOSEPH, PL
1001 Brickell Bay Drive, 32nd Floor
Miami, Florida 33131
Tel. (305) 350-5690
Fax (305) 371-8989
E-mail: Cdavid@
E-mail: Tdavid@ a
Secondary: Bvilllobos@fuerstlaw.
By: /s/ CHRISTOPHER M. DAVID
Florida Bar No. 985163
Thomas M. David
Florida Bar No. 20846
uerstlaw.com
Counsel for Florida Charter Foundation, Inc.
CERTIFICATE OF SERVICE
I hereby certify that on August 29, 2014, a copy of the foregoing was forwarded
via electronic mail. I electronically filed or caused to be filed the foregoing document
using Florida’s eFiling Portal. I also certify that the foregoing document is being served
this day on all counsel of record via the Electronic Service List associated with the
foregoing eFiling.
/s/ Christopher M. David
CHRISTOPHER M. DAVID
Florida Bar No. 985163
Document Filed Date
August 29, 2014
Case Filing Date
January 16, 2014
Category
Contract and Indebtedness
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Filing # 17668828 Electronically Filed 08/29/2014 09:59:23 AM 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, 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. / DEFENDANT'S RESPONSE TO PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS Defendant FLORIDA CHARTER FOUNDATION, INC., D/B/A FRANKLIN ACADEMY CHARTER SCHOOL, (hereinafter “Defendant”) by and through undersigned counsel, and pursuant to Rule 1.380 of the Florida Rules of Civil Procedure hereby respond to the Plaintiff's First Request for Admissions dated July 31, 2014 as follows: *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/29/2014 9:59:22 AM.****1. CASE NO.: CACE-14-001087 (04) The Defendant is unable to admit or deny the subject request. The Defendant engaged in good faith negotiations with the Plaintiff. Those negotiations did not result in a written contract. 2. Admitted. Denied. Denied. Denied. Denied. Admitted. Defendant received complaints from student's parents related to Planet T as well. 8. 9. 10. 11. 12. 13. 14. 15. Denied. Denied. “FRANKLIN” does not sell uniforms. Denied. “FRANKLIN” does not sell uniforms. Denied. “FRANKLIN” does not sell uniforms. Denied. “FRANKLIN” does not sell uniforms. Denied. Denied. The Defendant is unable to admit or deny request number 15 as phrased. The Defendant believes that its first contact with iUniforms was in the first quarter of 2013. The Defendant is unable to confirm whether its first contact with iUniforms related to iUniforms being an “exclusive” uniform vendor was prior to February 1, 2013.CASE NO.: CACE-14-001087 (04) Respectfully submitted, FUERST ITTLEMAN DAVID & JOSEPH, PL 1001 Brickell Bay Drive, 32nd Floor Miami, Florida 33131 Tel. (305) 350-5690 Fax (305) 371-8989 E-mail: Cdavid@ E-mail: Tdavid@ a Secondary: Bvilllobos@fuerstlaw. By: /s/ CHRISTOPHER M. DAVID Florida Bar No. 985163 Thomas M. David Florida Bar No. 20846 uerstlaw.com Counsel for Florida Charter Foundation, Inc. CERTIFICATE OF SERVICE I hereby certify that on August 29, 2014, a copy of the foregoing was forwarded via electronic mail. I electronically filed or caused to be filed the foregoing document using Florida’s eFiling Portal. I also certify that the foregoing document is being served this day on all counsel of record via the Electronic Service List associated with the foregoing eFiling. /s/ Christopher M. David CHRISTOPHER M. DAVID Florida Bar No. 985163