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MEMORANDUM OF LAW

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 957 (Florida State, Palm Beach County, Fifteenth Circuit Court Mar. 6, 2025)
Filing # 218227955 E-Filed 03/06/2025 12:48:03 PM NOT A CERTIFIED COPY FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 03/06/2025 12:48:03 PM NOT A CERTIFIED COPY NOT A CERTIFIED COPY
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ORDER G JOS CURLEY DTD 3/6/25 THAT THE MOTION IS GRANTED IN PART & DENIED IN PART AS FOLLOWS: **SEE ORDER**

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 958 (Florida State, Palm Beach County, Fifteenth Circuit Court Mar. 6, 2025)
Filing # 218270544 E-Filed 03/06/2025 05:01:31 PM WILLIAM J. PULTE, an individual, CASE NO.: 502022CA012238XXXXMB
THIS CAUSE, having come before the Court at the February 20, 2025 hearing on Non- Party Michelle Hairston’s Objections to Subpoena Duces Tecum, and having reviewed the Motion and being fully advised in the premises, the Court hereby ORDERS and ADJUDGES that the Motion is GRANTED in part and DENIED in part as follows:
Therefore, the Court will not address any issues relating to Plaintiff’s contentions regarding the sufficiency of Ms. Hairston’s production or lack thereof.
Ms. Hairston need not provide a privilege log.
United States Sugar Corp., v. Estate of Mullins, 211 So.3d 110 (Fla. 4th DCA 2017); DLJ Mortg.
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ORDER SETTING HEARING

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 952 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 28, 2025)
The following matters have been specially set for hearing before Judge G. Joseph Curley Jr.in Courtroom 11C, Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, FL 33401.
Each party has the option to appear either in person in the courtroom or electronically via Zoom*, using the following information:
Non-Parties PulteGroup Board Member’s Omnibus Motion for Protective Order, filed August 20, 2024; 3.
Non-Party Jim Zeumer’s Objections to Documents Requests Contained in Plaintiff’s Subpoena for Deposition, filed January 20, 2025; 4.
Accordingly, all counsel or self-represented parties must either: (1) be present in person or by Zoom conference at the hearing or (2) submit an Agreed Order disposing of the motion at least 48 business hours prior to the hearing.
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NOTICE OF FILING

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 950 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 27, 2025)
502022CA012238XXXXMB NOT A CERTIFIED COPY Filing # 217752916 E-Filed 02/27/2025 04:20:12 PM FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 02/27/2025 04:20:12 PM NOT A CERTIFIED COPY NOT A CERTIFIED COPY
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ORDER CURLEY DTD 2/24/25: MOTIONS TO COMPEL GRANTED IN AND PLT'S OBJECTIONS ARE OVERRULED IN PART ** SEE ORDER **

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 943 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 24, 2025)
THIS CAUSEcame before the Court on January 27, 2025, on Defendant, Brandon Jones’s Motion to Compel and Overrule Objectionsto Plaintiffs Response to Defendant’s Third Request for Production [D.E.
The Court, having reviewed the submissions of the parties, having heard argument of counsel, and otherwise being fully adyised in the premises, hereby JP?pot Lal AeT ORDERSandADJUDGESasfollows: 1, The“Motion$to Compel are GRANTED4nd Plaintiff's objections are overruled.”
The Courtnotes that Plaintiff's objections are nonspecific, and unsupported by the Florida Rules of Civil Procedure.
provide sworn certification to this Court (a) describatg the steps Plaintiff has taken to marshal and review documents tesponsive to Defendant’s Third
(be at eXKS Ths £ ~ asl tn gwernreyFs KES yaxX/ arn Aad Ku anv CASWENS @lae og Neer DEL hurt Wo sypfperT ay fark sede oa.
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ORDER ON PLT, WILLIAM J. PULTE'S MOTION FOR BRIEF STAY OF DISCOVERY PENDING PLT'S RECEIPT OF DOCUMENT PRODICTION [D.E. 761]: THE HEARIN GON THE MOTION IS DEFERRED. JUDGE CURLEY DTD 2/17/25

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 930 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 17, 2025)
THIS CAUSE came before the Court on December 27, 2024, at a special set hearing commencing at 10:00 a.m., on Plaintiff, William J. Pulte's, Motion for Brief Stay of Discovery Pending Plaintiff's Receipt of Document Production [D.E.
The Court, having considered Plaintiff's request that the Court defer consideration and hearing of the Motion at this time, hereby ORDERS and ADJUDGES, the hearing on the Motion is deferred.
DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida.
Copies to:
Case No. 50-2022-CA-012238-XXXX-MB Gregory W. Coleman, Esq. David R. Burchers, Esq. Samuel S. Cohen, Esq. CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Blvd., Suite 400 West Palm Beach, FL.
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EXHIBIT

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 934 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 17, 2025)
Additionally, Jones claims that he is missing text messages from December 2022-the same month that he was terminated, and this lawsuit was filed.
Given the significant events in that time period, and Ms. Hairston’s involvement in them given her position at PulteGroup, we anticipate there should be communications between Ms. Hairston and Jones that he has not provided.
Please provide an explanation of the process that you and/or Ms. Hairston undertook to search for responsive documents, including from her phone, personal emails, and social media.
If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited.
If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited.
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RESPONSE TO: NON-PARTY MICHELLE HAIRSTON'S MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITION AND OBJECTIONS TO SUBPOENA DUCES TECUM F/B PLT

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 931 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 17, 2025)
502022CA012238XXXXMB NOT A CERTIFIED COPY Filing # 216947403 E-Filed 02/17/2025 03:20:22 PM FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 02/17/2025 03:20:22 PM NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY
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MOTION TO VACATE PORTION OF COURT ORDER OR IN THE ALTERNATIVE MOTION FOR CLARIFICATION F/B NON PARTY PULTEGROUP, INC.

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 929 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 14, 2025)
THIS CAUSE came before the Court at a special set hearing on January 27, 2025 at 10:00 a.m. on Plaintiff's Motion To Compel PulteGroup, Inc. to Produce Documents the Court Previously Ordered filed December 9, 2024 (the "Motion").
The Court, having reviewed the submissions of the parties, heard argument of counsel, and being otherwise fully advised in the premises, hereby ORDERS and ADJUDGES that the Motion is GRANTED, in part, as follows:
The court notes that independent of the is order, the documents may be subject to production under the amended rules of civil procedure as either a supplement or a disclosure.
The Court will set a Case Management Conference on any remaining issues.
_________________________/ supplemental Order on Plaintiff’s Motion to Compel Documents from PulteGroup THIS CAUSE having come before the Court during a special set hearing on January 27, 2025, on Plaintiff’s Motion to Compel PulteGroup, Inc. to Produce Documents the Court Previously Ordered (“Motion”).
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RESPONSE TO: OPPOSITION TO NON-PARTY SHARON MCDONALDS MOTION FOR PROTECTIVE ORDER TO IMPOSE A GAG ORDER/NO POSTING CONDITION AND TO REQUIRE DEPOSITION UPON WRITTEN QUESTIONS F/B PLT

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 925 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 10, 2025)
502022CA012238XXXXMB NOT A CERTIFIED COPY Filing # 216411587 E-Filed 02/10/2025 12:32:10 PM FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 02/10/2025 12:32:10 PM NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY NOT A CERTIFIED COPY
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ORDER CURLEY: (SUPPLEMENTAL) ON PLAINTIFFS MOTION TO COMPEL DOCUMENTS FROM PULTEGROUP DTD 2-7-25

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 912 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 7, 2025)
_________________________/ supplemental Order on Plaintiff’s Motion to Compel Documents from PulteGroup THIS CAUSE having come before the Court during a special set hearing on January 27, 2025, on Plaintiff’s Motion to Compel PulteGroup, Inc. to Produce Documents the Court Previously Ordered (“Motion”).
The Court, having reviewed the submissions of counsel and heard arguments of counsel, it is hereby ORDERED as follows as to those issues and documents that the first order of same date DOES NOT address.
Plaintiff shall review the Log of Files Not Produced (served October 30, 2024) and the Log of Responsive But Not Relevant Files (served November 19, 2024) previously provided by non-party PulteGroup (the “Logs”).
Plaintiff must then identify the specific documents from the Logs about which Plaintiff alleges he is entitled to additional information.
DONE AND ORDERED in Chambers in Palm Beach County, Florida.
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ORDER G JOS CURLEY DTD 2/7/25 REGARDING SUBPOENAS - TO THE EXTENT THAT A DEPOSITION OF A NONPARTY NEEDS TO BE RESCHEDULED FOR ANY REASON, ANY SUBPOENA THAT HAS BEEN SERVED WILL NOT BE NEED TO BE RE-SERVED.

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 913 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 7, 2025)
THIS CAUSE came before the Court on January 27, 2025, on the ore tenus agreement of counsel as to the subpoenas of Victor Rancour, Rancour Ventures, LLC, and Diana Pulte.
The Court, upon the agreement of counsel and having been duly advised in the premises, hereby ORDERS and ADJUDGES as follows: To the extent that a deposition of a nonparty needs to be rescheduled for any reason, any subpoena that has been served will not need to be re-served.
DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida.
600 Peachtree Street, N.E.
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ORDER J. CURLEY DTD 2/7/25: PLAINTIFF'S MOTION TO COMPEL PULTEGROUP, INC. TO PRODUCE DOCUMENTS THE COURT PREVIOUSLY ORDERED - GRANTED IN PART. **SEE ORD FOR DETAILS**

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 915 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 7, 2025)
THIS CAUSE came before the Court at a special set hearing on January 27, 2025 at 10:00 a.m. on Plaintiff's Motion To Compel PulteGroup, Inc. to Produce Documents the Court Previously Ordered filed December 9, 2024 (the "Motion").
The Court, having reviewed the submissions of the parties, heard argument of counsel, and being otherwise fully advised in the premises, hereby ORDERS and ADJUDGES that the Motion is GRANTED, in part, as follows: 1.
The court notes that independent of the is order, the documents may be subject to production under the amended rules of civil procedure as either a supplement or a disclosure.
The Court will set a Case Management Conference on any remaining issues.
Circuit Judge Copies to parties on attached service list
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AGREED ORDER J. CURLEY DTD 2/7/25: WITHDRAWING DEFENDANT, BRANDON JONES' FOURTH REQUEST FOR ADMISSIONS TO PLAINTIFF.

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 916 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 7, 2025)
THIS CAUSE came before the Court upon the agreement of the parties, on Plaintiff, William J. Pulte's ("Pulte") Motion for Protective Order or, in the Alternative, Motion to Strike Defendant's Fourth Set of Request for Admissions to Plaintiff, filed on November 22, 2024.
The Court, having reviewed the submissions of the parties, and being otherwise fully advised in the
Defendant, Brandon Jones' ("Jones") Fourth Request for Admissions filed on November 19, 2024 is withdrawn.
Pulte does not need to respond to Jones' Fourth Request for Admissions.
DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida.
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ORDER G JOS CURLEY DTD 2/7/25 THAT THE MOTION IS GRANTED IN PART AS FOLLOWS: **SEE ORDER FOR DETAILS**

Document PULTE, WILLIAM J V JONES, BRANDON, 50-2022-CA-012238-XXXX-MB, No. 917 (Florida State, Palm Beach County, Fifteenth Circuit Court Feb. 7, 2025)
THIS CAUSE came before the Court at a special set hearing on January 27, 2025 at 10:00 a.m. on Plaintiff's Motion For Sanctions Against Ryan Marshall For Violating A Court Order To Produce Documents By July 22, and For Order To Show Cause Why Ryan Marshall Should Not Be Held In Contempt of Court filed August 15, 2024 (the "Motion").
The Court, having reviewed the submissions of the parties, heard argument of counsel, and being otherwise fully advised in the premises, hereby ORDERS and ADJUDGES that the Motion is Granted, in part, as follows: 1.
Should the Fourth District Court of Appeal deny Marshall’s Motion for Rehearing and Rehearing En Banc, Marshall has 10 days to produce the documents requested by Plaintiff in the manner already ruled upon.
Should Marshall fail to produce the documents within 10 days, there will be sanctions such as the cost of holding up the proceedings in this matter and of these motions if production does not occur within 10 days in a manner already ruled upon.
Circuit Judge Copies to parties on attached Service List
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