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Filing # 139430322 E-Filed 12/01/2021 08:54:42 AM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR LEE COUNTY, FLORIDA
SAMUEL GEORGE SCHULTZ,
CASE NO. 21-CA-000387
Plaintiff,
v.
JUPITER INDUSTRIES LLC and
WILLIAM JAMES FULLER,
Defendants.
___________________________________/
DEFENDANT, JUPITER INDUSTRIES LLC’S RESPONSE TO
PLAINTIFF’S THIRD REQUEST TO PRODUCE
COMES NOW, the Defendant, JUPITER INDUSTRIES LLC, by and through its
undersigned counsel and pursuant to Rule 1.350, Fla. R. Civ. P., hereby files its Response to Plaintiff,
SAMUEL GEORGE SCHULTZ’s, Third Request to Produce dated November 1, 2021, as follows:
1. The complete personnel file, cover to cover, maintained by Jupiter Industries, LLC on William
James Fuller, including his application for employment, job descriptions, documents of
discipline or job re-assignment, computer searches on his driving history and insurability,
traffic infractions (if any), and emails concerning William James Fuller’s employment with
Jupiter Industries LLC.
RESPONSE: Objection, overly broad, unduly burdensome, vague, ambiguous, irrelevant,
immaterial, and not reasonably calculated to lead to the discovery of admissible evidence.
Clooney v. Geeting, 352 So. 2d 1216 (Fla. 2d DCA 1977).
2. Any and all photos or video recordings taken at the scene of the incident giving rise to the
above-styled lawsuit, including any and all photo or video of any person, object or thing at
the scene of the subject incident.
eFiled Lee County Clerk of Courts Page 1
Schultz v. Jupiter Industries LLC, et al.
Case No. 21-CA-000387, Div. T
Defendant, Jupiter Industries, LLC’s Response to Plaintiff’s Third Request to Produce
RESPONSE: No video recordings were taken. All such photographs were produced by former
employee Michael Snyder at his deposition.
3. Any and all photos or video recordings taken after leaving the scene of the incident giving rise
to the above-styled lawsuit which depict any person, object or thing involved in or related to
the subject incident.
RESPONSE: No video recordings were taken. Objection, work product as to photographs:
Privilege Log: Defendants are in possession of six (6) color photographs taken
of Defendant’s truck at the Jupiter Industries Warehouse following the
accident by former Manager Michael Snyder.
4. Any and all notes, reports, recordings, or records, pertaining to or arising from any
investigation concerning the incident giving rise to the above-styled lawsuit.
RESPONSE: Objection, any such notes or reports were prepared either in anticipation of
litigation and are thus protected as work product and/or involve communications protected by
the attorney-client privilege.
5. Any and all communication logs – including, but not limited to, cellular telephone records,
electronic communication records, etc. – pertaining to the communications or, by, or with
William James Fuller on October 1, 2020.
RESPONSE: None in possession of Defendant.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served on this 1st
day of December, 2021 to all parties listed via E-Portal Service including but not limited to the
following: Preston John Scheiner, Esq. and Daniel Dalesandro, Esq.; service@blslawyers.com;
service2.bls@gmail.com The certificate is taken as prima facie proof of such service in
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eFiled Lee County Clerk of Courts Page 2
Schultz v. Jupiter Industries LLC, et al.
Case No. 21-CA-000387, Div. T
Defendant, Jupiter Industries, LLC’s Response to Plaintiff’s Third Request to Produce
compliance with Fla. R. Jud. Admin. 2.516.
/s/ Kaitlin Cupp Jensen
MICHAEL D. LOGAN, ESQUIRE
Florida Bar No. 504531
KAITLIN CUPP JENSEN, ESQUIRE
Florida Bar No. 111440
TRAUB LIEBERMAN STRAUS & SHREWSBERRY, LLP
11770 U.S. Highway One, Suite 402E
Palm Beach Gardens, Florida 33408
Telephone: (561) 848-8300
Email Designations:
MLogan@tlsslaw.com
KJensen@tlsslaw.com
PBGPleadings@tlsslaw.com
Page 3 of 3
eFiled Lee County Clerk of Courts Page 3
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Filing # 139430322 E-Filed 12/01/2021 08:54:42 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR LEE COUNTY, FLORIDA SAMUEL GEORGE SCHULTZ, CASE NO. 21-CA-000387 Plaintiff, v. JUPITER INDUSTRIES LLC and WILLIAM JAMES FULLER, Defendants. ___________________________________/ DEFENDANT, JUPITER INDUSTRIES LLC’S RESPONSE TO PLAINTIFF’S THIRD REQUEST TO PRODUCE COMES NOW, the Defendant, JUPITER INDUSTRIES LLC, by and through its undersigned counsel and pursuant to Rule 1.350, Fla. R. Civ. P., hereby files its Response to Plaintiff, SAMUEL GEORGE SCHULTZ’s, Third Request to Produce dated November 1, 2021, as follows: 1. The complete personnel file, cover to cover, maintained by Jupiter Industries, LLC on William James Fuller, including his application for employment, job descriptions, documents of discipline or job re-assignment, computer searches on his driving history and insurability, traffic infractions (if any), and emails concerning William James Fuller’s employment with Jupiter Industries LLC. RESPONSE: Objection, overly broad, unduly burdensome, vague, ambiguous, irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence. Clooney v. Geeting, 352 So. 2d 1216 (Fla. 2d DCA 1977). 2. Any and all photos or video recordings taken at the scene of the incident giving rise to the above-styled lawsuit, including any and all photo or video of any person, object or thing at the scene of the subject incident. eFiled Lee County Clerk of Courts Page 1 Schultz v. Jupiter Industries LLC, et al. Case No. 21-CA-000387, Div. T Defendant, Jupiter Industries, LLC’s Response to Plaintiff’s Third Request to Produce RESPONSE: No video recordings were taken. All such photographs were produced by former employee Michael Snyder at his deposition. 3. Any and all photos or video recordings taken after leaving the scene of the incident giving rise to the above-styled lawsuit which depict any person, object or thing involved in or related to the subject incident. RESPONSE: No video recordings were taken. Objection, work product as to photographs: Privilege Log: Defendants are in possession of six (6) color photographs taken of Defendant’s truck at the Jupiter Industries Warehouse following the accident by former Manager Michael Snyder. 4. Any and all notes, reports, recordings, or records, pertaining to or arising from any investigation concerning the incident giving rise to the above-styled lawsuit. RESPONSE: Objection, any such notes or reports were prepared either in anticipation of litigation and are thus protected as work product and/or involve communications protected by the attorney-client privilege. 5. Any and all communication logs – including, but not limited to, cellular telephone records, electronic communication records, etc. – pertaining to the communications or, by, or with William James Fuller on October 1, 2020. RESPONSE: None in possession of Defendant. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served on this 1st day of December, 2021 to all parties listed via E-Portal Service including but not limited to the following: Preston John Scheiner, Esq. and Daniel Dalesandro, Esq.; service@blslawyers.com; service2.bls@gmail.com The certificate is taken as prima facie proof of such service in Page 2 of 3 eFiled Lee County Clerk of Courts Page 2 Schultz v. Jupiter Industries LLC, et al. Case No. 21-CA-000387, Div. T Defendant, Jupiter Industries, LLC’s Response to Plaintiff’s Third Request to Produce compliance with Fla. R. Jud. Admin. 2.516. /s/ Kaitlin Cupp Jensen MICHAEL D. LOGAN, ESQUIRE Florida Bar No. 504531 KAITLIN CUPP JENSEN, ESQUIRE Florida Bar No. 111440 TRAUB LIEBERMAN STRAUS & SHREWSBERRY, LLP 11770 U.S. Highway One, Suite 402E Palm Beach Gardens, Florida 33408 Telephone: (561) 848-8300 Email Designations: MLogan@tlsslaw.com KJensen@tlsslaw.com PBGPleadings@tlsslaw.com Page 3 of 3 eFiled Lee County Clerk of Courts Page 3