Preview
Filing # 100280416 E-Filed 12/13/2019 11:34:13 AM
IN THE CIRCUIT COURT FOR THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY FLORIDA
PEADEN, LLC,
Plaintiff,
ve Case No.: 19-CA-3214
RICHARD SISK, ERIC LUDWIG,
VIVIENNE REILLY, and CHERI STEWART,
Defendants.
/
RESPONSE TO REQUEST TO PRODUCE TO DEFENDANT
Defendant, Cheri Stewart, pursuant to Florida Rule of Civil Procedure 1.350,
hereby responds to Plaintiffs First Request for Production as follows:
1, Defendant is aware of no documents responsive to this request.
2. Attached hereto as Exhibit “A” is the Holiday Beach Rentals Development
Earnings Report, which shows defendant Stewart's compensation to date.
3. Attached as Exhibit “B” is the letter from HBRD offering defendant Stewart the
job and laying out the terms of employment.
4. None.
5. None.
6. See Exhibit "A."
7. Attached hereto as Exhibit "C" is the Holiday Beach mechanical project list.
8. I resigned from Peaden, due to being unjustly demoted from my position asLead Accountant for Peaden Air Conditioning, Plumbing and Electrical Service/Retro
Division and placed in a menial coordinator position. I suffered a significant cut in pay
as well as the embarrassment and emotional distress from the entire company seeing
that I was demoted with no justification. It was common knowledge that I was demoted
due to Madeline Daws dislike for me. She seemed to have a personal grudge against me
as she did others.
9. See Exhibit "B."
10. None.
11. None.
12. None.
13, None.
14. None.
15. None.
16. None.
17. None.
18. No decision has yet been made regarding trial exhibits.
19. Defendant objects to this request because it intrudes upon work product
immunity. Subject to the foregoing objection, and without waiving same, none.
20. From January 1, 2018 until present, I only had my personal phone.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that at true and correct copy of the foregoing was delivered to
William S. Henry at BURKE BLUE located at 221 McKenzie Avenue, Panama City,
Florida 32401 on this 13" day of December, 2019.
DUNLAP & SHIPMAN, P.A.
Michael P. Dickey
Florida Bar #115606
2063 S. County Hwy. 395
Santa Rosa Beach, FL 32459
(850) 231-3315
Primary: mdickey@dunlapshipman.com
Secondary:
amberley@dunlapshipman.com
ATTORNEYS FOR DEFENDANTPayroll Check Register
11720118
Holiday Beach Rentals Development Inc
Payroll Check Register
by Employee
mployae = 26, Period End 08/12/2019 to 11/20/2019
Record# Check# Date Gross Add Deduct Net
26 Chery! Stewart
401 46 08/21/2019 1,250.00 272.44 977,88
417 16 08/28/2019 4,250.00 272.14 977.86
432.15 op/o4/2019 1,250.00 272.44 977.86
448 15 09/11/2019 4,250.00 272.14 977.88
462 14 09/18/2019 4,250.00 272.44 977.86
476 14 09/26/2019 4,250.00 272.44 977.88
400 14 10/02/2019 4250.00 272.14 977.86
504 14 40/09/2018 4,250.00 272.44 977.86
518 14 s0s6/2019 4,250.00 272.14 977.86
532 14 10/23/2018 4,250.00 272.14 977.86
B46 44 10/30/2019 1,250.00 272.44 977.86
B60 14 1106/2019 1,250.00 272.14 977.86
873 43 1493/2018 4,250.00 272.44 977.88
585 12 11/20/2019 1,250.00 272.14 977.86
Employee Totals: 17,800.00 3,808.95 13,690.04
Grand Totals: 17,500.00 3,809.96 13,690.04
Report 5-1-2-36 1120/19
Mary Page 1of4 40:45 ANJason Roberts
17614 Ashley Drive
Panama City Beach, FL 32413
850.251.0973 Jason
jason@holidaybeachre
July 18, 2019
Cheryl A, Stewart
5322 Stewart Drive
Panama City, FL 32404
Dear Cheryl:
On behalf of Holiday Beach Rentals Development, Inc. | am pleased to offer you the position of Accounting
Specialist with an anticipated start date of August 12, 2019.
This job is classified as administrative non-exempt and is an at-will position and elther party may terminate the
employment relationship at any time with or without cause and with or without notice.
Your beginning rate of compensation will be an annual salary of $65,000, Your first performance review will be
In 3 months and you will report directly to Matt Gerrell,
Additionally, you will be entitled to 10 days of paid vacation and 5 days of sick leave per year of employment to
begin after your first performance review. Vacation and sick leave must be requested and taken in accordance
with our company’s policies, procedures and employee handbook as adopted, revised or deleted from time to
time.
1 lock forward to a positive working relationship. Please sign below indicating your acceptance of the terms
and conditions of this offer.
Sincerely,
Jason Roberts
i accept the terms and conditions of this offer.
hari Senior 82/4Jobe
201901
201902
1920001
1920003
4920004
3920005
1920010
1920011
2018281
2018401
2018421
2019031
2019032
2019033
2019081
2019111
2019112
2019133
2019131
2019332
2019133
2039141
2019242
2019143
2019162
2019162
2019163
2019171
2019172
2019173
2019181
2019182
2019202
2019211
2019212
2019213
2019221
2019222
2019223
2019231
2019232
2019233
2019241
2019242
2019243
2019261
2019262
2019263
Job Name
Service - Holiday Beach Rentals
Holiday Beach Rentals Development
James M Hurst
Jason Clutch
Carol Beaucage
Lot 32 Grace Point - Electrical
Jobs - Nonbillable all trades
‘Warranty ~ Callback all trades
Fasth 721 Wild Heron Lot S - Electrical
Wild Heron Way Lot 6 - Electrical
709 Wild Heron Way Lot 8 - Electrical
Matt's Palace - Electrical
Matt's Palace - HVAC
Matt's Palace - Plumbing
728 Wild Heron Way Lot 2- Electrical
Bluff House ti - HVAC
Bluff House il - Electrical
Bluff House Il - Plumbing
Rod Shaw - Electrical
Rod Shaw - HVAC
Rod Shaw -Plumbing
Greg Hasley - Electrical
Greg Haslely - HVAC
Greg Hasley - Plumbing
Hasley 75 East - Electrical
Hasley 75 East -HVAC
Hasley 75 East ~ Plumbing
Hasley 75 West - Electrical
Hasley 75 West - HVAC
Masley 75 West - Plumbing
Rivercamp Houses - Electrical
River Camp Houses - HVAC
St. Joe Windmark - HVAC
Matt Broms West A4 Electrical
Matt Broms West A4- HVAC
Matt Broms West A4 - Plumbing
Greg Dolezal/GD investments 83 -Electrical
Greg Dolezal/GD Investments B3 - HVAC
‘Greg Dolezal/GD Investments B3 - Plumbing
Can't Top This C2 -Electrical
Can't Top This C2 -HVAC
Can't Top This C2 -Plumbing
Can't Top This D1 East - Electrical
Can't Top This D1 East -HVAC
Can't Top This D1 East - Plumbing
Matts Pier Park - Electrical
Matts Pler Park - HVAC
Matts Pier Park - Plumbing
Preview
Filing # 100280416 E-Filed 12/13/2019 11:34:13 AM IN THE CIRCUIT COURT FOR THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY FLORIDA PEADEN, LLC, Plaintiff, ve Case No.: 19-CA-3214 RICHARD SISK, ERIC LUDWIG, VIVIENNE REILLY, and CHERI STEWART, Defendants. / RESPONSE TO REQUEST TO PRODUCE TO DEFENDANT Defendant, Cheri Stewart, pursuant to Florida Rule of Civil Procedure 1.350, hereby responds to Plaintiffs First Request for Production as follows: 1, Defendant is aware of no documents responsive to this request. 2. Attached hereto as Exhibit “A” is the Holiday Beach Rentals Development Earnings Report, which shows defendant Stewart's compensation to date. 3. Attached as Exhibit “B” is the letter from HBRD offering defendant Stewart the job and laying out the terms of employment. 4. None. 5. None. 6. See Exhibit "A." 7. Attached hereto as Exhibit "C" is the Holiday Beach mechanical project list. 8. I resigned from Peaden, due to being unjustly demoted from my position asLead Accountant for Peaden Air Conditioning, Plumbing and Electrical Service/Retro Division and placed in a menial coordinator position. I suffered a significant cut in pay as well as the embarrassment and emotional distress from the entire company seeing that I was demoted with no justification. It was common knowledge that I was demoted due to Madeline Daws dislike for me. She seemed to have a personal grudge against me as she did others. 9. See Exhibit "B." 10. None. 11. None. 12. None. 13, None. 14. None. 15. None. 16. None. 17. None. 18. No decision has yet been made regarding trial exhibits. 19. Defendant objects to this request because it intrudes upon work product immunity. Subject to the foregoing objection, and without waiving same, none. 20. From January 1, 2018 until present, I only had my personal phone.CERTIFICATE OF SERVICE I HEREBY CERTIFY that at true and correct copy of the foregoing was delivered to William S. Henry at BURKE BLUE located at 221 McKenzie Avenue, Panama City, Florida 32401 on this 13" day of December, 2019. DUNLAP & SHIPMAN, P.A. Michael P. Dickey Florida Bar #115606 2063 S. County Hwy. 395 Santa Rosa Beach, FL 32459 (850) 231-3315 Primary: mdickey@dunlapshipman.com Secondary: amberley@dunlapshipman.com ATTORNEYS FOR DEFENDANTPayroll Check Register 11720118 Holiday Beach Rentals Development Inc Payroll Check Register by Employee mployae = 26, Period End 08/12/2019 to 11/20/2019 Record# Check# Date Gross Add Deduct Net 26 Chery! Stewart 401 46 08/21/2019 1,250.00 272.44 977,88 417 16 08/28/2019 4,250.00 272.14 977.86 432.15 op/o4/2019 1,250.00 272.44 977.86 448 15 09/11/2019 4,250.00 272.14 977.88 462 14 09/18/2019 4,250.00 272.44 977.86 476 14 09/26/2019 4,250.00 272.44 977.88 400 14 10/02/2019 4250.00 272.14 977.86 504 14 40/09/2018 4,250.00 272.44 977.86 518 14 s0s6/2019 4,250.00 272.14 977.86 532 14 10/23/2018 4,250.00 272.14 977.86 B46 44 10/30/2019 1,250.00 272.44 977.86 B60 14 1106/2019 1,250.00 272.14 977.86 873 43 1493/2018 4,250.00 272.44 977.88 585 12 11/20/2019 1,250.00 272.14 977.86 Employee Totals: 17,800.00 3,808.95 13,690.04 Grand Totals: 17,500.00 3,809.96 13,690.04 Report 5-1-2-36 1120/19 Mary Page 1of4 40:45 ANJason Roberts 17614 Ashley Drive Panama City Beach, FL 32413 850.251.0973 Jason jason@holidaybeachre July 18, 2019 Cheryl A, Stewart 5322 Stewart Drive Panama City, FL 32404 Dear Cheryl: On behalf of Holiday Beach Rentals Development, Inc. | am pleased to offer you the position of Accounting Specialist with an anticipated start date of August 12, 2019. This job is classified as administrative non-exempt and is an at-will position and elther party may terminate the employment relationship at any time with or without cause and with or without notice. Your beginning rate of compensation will be an annual salary of $65,000, Your first performance review will be In 3 months and you will report directly to Matt Gerrell, Additionally, you will be entitled to 10 days of paid vacation and 5 days of sick leave per year of employment to begin after your first performance review. Vacation and sick leave must be requested and taken in accordance with our company’s policies, procedures and employee handbook as adopted, revised or deleted from time to time. 1 lock forward to a positive working relationship. Please sign below indicating your acceptance of the terms and conditions of this offer. Sincerely, Jason Roberts i accept the terms and conditions of this offer. hari Senior 82/4Jobe 201901 201902 1920001 1920003 4920004 3920005 1920010 1920011 2018281 2018401 2018421 2019031 2019032 2019033 2019081 2019111 2019112 2019133 2019131 2019332 2019133 2039141 2019242 2019143 2019162 2019162 2019163 2019171 2019172 2019173 2019181 2019182 2019202 2019211 2019212 2019213 2019221 2019222 2019223 2019231 2019232 2019233 2019241 2019242 2019243 2019261 2019262 2019263 Job Name Service - Holiday Beach Rentals Holiday Beach Rentals Development James M Hurst Jason Clutch Carol Beaucage Lot 32 Grace Point - Electrical Jobs - Nonbillable all trades ‘Warranty ~ Callback all trades Fasth 721 Wild Heron Lot S - Electrical Wild Heron Way Lot 6 - Electrical 709 Wild Heron Way Lot 8 - Electrical Matt's Palace - Electrical Matt's Palace - HVAC Matt's Palace - Plumbing 728 Wild Heron Way Lot 2- Electrical Bluff House ti - HVAC Bluff House il - Electrical Bluff House Il - Plumbing Rod Shaw - Electrical Rod Shaw - HVAC Rod Shaw -Plumbing Greg Hasley - Electrical Greg Haslely - HVAC Greg Hasley - Plumbing Hasley 75 East - Electrical Hasley 75 East -HVAC Hasley 75 East ~ Plumbing Hasley 75 West - Electrical Hasley 75 West - HVAC Masley 75 West - Plumbing Rivercamp Houses - Electrical River Camp Houses - HVAC St. Joe Windmark - HVAC Matt Broms West A4 Electrical Matt Broms West A4- HVAC Matt Broms West A4 - Plumbing Greg Dolezal/GD investments 83 -Electrical Greg Dolezal/GD Investments B3 - HVAC ‘Greg Dolezal/GD Investments B3 - Plumbing Can't Top This C2 -Electrical Can't Top This C2 -HVAC Can't Top This C2 -Plumbing Can't Top This D1 East - Electrical Can't Top This D1 East -HVAC Can't Top This D1 East - Plumbing Matts Pier Park - Electrical Matts Pler Park - HVAC Matts Pier Park - Plumbing