`
`IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT,
`IN AND FOR PALM BEACH COUNTY, FLORIDA
`
`
`
`CASE NO.: 2023-CA-001432
`
`Plaintiff,
`
`
`CHENEY BROS., INC.,
`a Florida Corporation,
`
`
`
`vs.
`
`WESLEY RICHARDS,
`
`Defendant.
`
`____________________________________________/
`
`
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`PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT
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`NOT A CERTIFIED COPY
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`Plaintiff, CHENEY BROS., INC.(“CBI”), by and through its undersigned attorneys,
`
`pursuant to Rule 1.350, Florida Rules of Civil Procedure, request the Defendant to produce the
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`following documents at the offices of the undersigned counsel for inspection and/or copying
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`within the time specified by the aforementioned Rule and Rule 1.090(e), Florida Rules of Civil
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`Procedure, or at such other place and time as may be agreed upon by counsel:
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`Definitions
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`A.
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`B.
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`C.
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`The terms "document" and "documentation" are defined, in addition to their common
`meanings, as the original or any copy, electronic copy, excerpt, photocopy, or facsimile
`of all written, printed, typed, recorded, or graphic matter, photographic matter, and sound
`reproduction of tapes or other devices, however produced or reproduced, in the actual or
`constructive possession, custody, or control of the party or party's representative, which
`documents include, but are not limited to, letters, telegrams, memoranda, reports, studies,
`calendars of daily entries, minutes, pamphlets, notes, charts, tabulations, and records of
`meetings, conferences, and telephone or other conversations or communications.
`The term "you" means the person(s), corporation(s), or other entities to which this
`Request is directed.
`
`The term "correspondence" means any letter, memorandum, note, on paper or stored
`electronically, including emails, reflecting or constituting a communication between two
`(2) people or among more than two (2) people.
`
`
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/10/2023 02:37:37 PM ***
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`
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`CASE NO.: 2023-CA-001432
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`
`Documents Requested
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`NOT A CERTIFIED COPY
`
`Any and all correspondence between you and CBI related to your employment with CBI
`(2018-2023).
`
`Any and all correspondence between you and CBI related to your aircraft training and
`qualifications.
`
`Any and all documents concerning your application for employment with CBI.
`
`Any and all documents that you provided to CBI in support of your application for
`employment.
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`Any and all documents related to your compensation during your employment with CBI,
`including, but not limited to, salary, bonus, health/life/disability insurance and other
`benefits.
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`Any and all documents concerning your severance from CBI.
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`Any and all applications for employment with Presidential Aviation, Inc.
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`Any and all documents provided to Presidential Aviation, Inc. regarding employment and
`as part of the employment application.
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`Any and all correspondence with Presidential Aviation, Inc.
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`Any and all documents exchange by you with Presidential Aviation, Inc.
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`Any and all applications for employment for the years 2018 – 2023.
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`Any and all documents provided by you in support of your application for employment
`for the years 2018 – 2023.
`
`A copy of your 2022 Resume/Curriculum Vitae.
`
`A copy of your 2023 Resume/Curriculum Vitae.
`
`Any and all documents provided to you by CBI necessary for you to perform your duties
`while employed by CBI, including, but not limited to, training manuals job descriptions,
`aircraft flight manuals or other documents utilized for your job.
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`Any and all copies of your current job description.
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`Any and all documents demonstrating all aircraft flight certifications held by you from
`2018 to the present.
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`2
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`17.
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`CASE NO.: 2023-CA-001432
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`Any and all documents for flight or aircraft training programs you participated in from
`2018 to the present.
`Any and all documents related to your training in the Citation XLS, Citation 560.
`Any and all documents related to your training and upgraded certification for the Citation
`Sovereign aircraft.
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`Any and all documents
`related to payment
`for certifications,
`requirements for you to perform your duties while employed at CBI.
`Any and all documents related to payment for your training and upgraded certification for
`the Citation Sovereign aircraft.
`Any and all cell phone records for October 2022, November 2022, December 2022 and
`January 2022.
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`licenses or other
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`Any and all Tax Returns with supporting documents for the years 2020-2022.
`A copy of your Pilot logbook.
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`18.
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`22.
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`23.
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`24.
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`25.
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`NOT A CERTIFIED COPY
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-
`portal this 10th day of March, 2023, to: Beth Coke, Esq., Coke Employment Law, 131 N. 2nd
`Street,, Suite 204, Fort Pierce, FL 34950 (beth@cokeemploymentlaw.com).
`
`WYLAND & TADROS LLP
`Attorneys for Plaintiff
`2505 Metrocentre Blvd., 2ndFloor
`West Palm Beach, FL 33407
`Tel. No.: (561)275-2990
`dtadros@wylandtadros.com
`atharp@wylandtadros. com
`
`BY: /s/David S. Tadros_
`
`DAVID S. TADROS, ESQ.
`FBN 956015
`CHARLES ANDREW THARP, ESQ.
`FBN 0746134
`
`3
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