Defendant has present case, similarly provided unequivocal testimony, by declaration and at deposition, that none of these individuals (or anyone else at PulteGroup) was involved in or had any knowledge of the alleged conduct that ...

NOT A CERTIFIED COPY None of this is enough to burden Sheldon, Zeumer, and the Board Members with further discovery from Plaintiff. B. The Court Should Protect the Nonparties from the Apex Depositions The threshold issues for ...

The Board seeks a protective order to avoid being deposed pursuant to deposition noticesThe Board seeks a protective order to avoid being deposed pursuant to deposition notices Plaintiff filed on June 14, 2024.

He trades in his grandfather’s legacy as if he had something to do with it.” Id. athad something to do with it.” Id. at Pulte tweeted about the turnaround ofPulte Homes that he and his grandfather orchestratedPulte tweeted about the turnaround ofPulte Homes that he and his grandfather orchestrated in 2016, to which Jones replied on February 19, 2022 using the fake @stephen_matthein 2016, to which Jones replied on February 19, 2022 using the fake @stephen_matthe account, “Employees hated him.

They lost their jobs because of him.” Id. at Pulte tweeted about his grandpa trusting him with Wall Street investors, bringing in ElliottPulte tweeted about his grandpa trusting him with Wall Street investors, bringing in Elliott Management who endorsed Pulte’s case for change, and turning around PulteGroup inManagement who endorsed Pulte’s case for change, and turning around PulteGroup in 2016.

The apex doctrine is designed to prohibit a party from noticing the deposition of a high-The apex doctrine is designed to prohibit a party from noticing the deposition of a high- ranking executive of a company who does not have unique, personal knowledge of the matters atranking executive of a company who does not have unique, personal knowledge of the matters at issue in the lawsuit where requiring the officer to sit for the deposition serves no purpose otherissue in the lawsuit where requiring the officer to sit for the deposition serves no purpose other than to harass and burden the company and disrupt the executive’s ability to meet their obligationsthan to harass and burden the company and disrupt the executive’s ability to meet their obligations integral to their position.

P. 1.280(h); Tesla, Inc. v. Monserratt, 384 So.3d 194, 197-98 (Fla. 4th DCA 2024) (in wrongful death case against Tesla asserting claim of negligence,197-98 (Fla. 4th DCA 2024) (in wrongful death case against Tesla asserting claim of negligence, plaintiff was prohibited from deposing Elon Musk because he had no unique, personal knowledgeplaintiff was prohibited from deposing Elon Musk because he had no unique, personal knowledge ofdiscoverable information and “requiring Mr. Musk to sit for a deposition would serve no purposeofdiscoverable information and “requiring Mr. Musk to sit for a deposition would serve no purpose other than to harass and burden Tesla and disrupt Mr. Musk’s ability to meet his obligations toother than to harass and burden Tesla and disrupt Mr. Musk’s ability to meet his obligations to consumers, stockholders, Tesla’s employees, and other activities integral to his position as CEO”).consumers, stockholders, Tesla’s employees, and other activities integral to his position as CEO”).

She is listed by Defendant as a trial fact witness “[l]ikely to have knowledge as to Plaintiff’s allegations and purported damages.” D.E.

the Court held a hearing on Defendant’s Objections tothe Court held a hearing on Defendant’s Objections to On January 27, 2025,On January 27, 2025, Plaintiff’s Notice of Intent to Serve Subpoena Duces Tecum on Nancy Rickard (D.E.

Although Ms. Rickard claims she does not know Defendant Brandon JonesAlthough Ms. Rickard claims she does not know Defendant Brandon Jones (“Jones”) and has no knowledge of his Tweets and social media posts prior to this litigation, Jones(“Jones”) and has no knowledge of his Tweets and social media posts prior to this litigation, Jones used Ms. Rickard’s posts to attack Pulte.

Request Nos. 2 through 5 of the document subpoena are narrowly-tailored to seekRequest Nos. 2 through 5 of the document subpoena are narrowly-tailored to seek information relevant to this litigation and discoverable as to the claims and defenses assertedinformation relevant to this litigation and discoverable as to the claims and defenses asserted therein.therein.

For the reasons stated herein, Non-Party Nancy Rickard’s Motion to Quash And forFor the reasons stated herein, Non-Party Nancy Rickard’s Motion to Quash And for Protective Order should be denied, and her objections to the document requests therein, should beProtective Order should be denied, and her objections to the document requests therein, should be overruled.overruled.

Plaintiff, WILLIAM J. PULTE (“Pulte” and/or “Plaintiff’), by and through undersigned counsel, hereby files his Opposition to Non-Party Todd Sheldon’s (“Sheldon”) Motion for Protective Order (D.E.

Sheldon seeks a protective order to avoid being deposed pursuant to a deposition notice Plaintiff filed on June 14, 2024.

The apex doctrine is designed to prohibit a party from noticing the deposition of a high- ranking executive of a company who does not have unique, personal knowledge of the matters at issue in the lawsuit where requiring the officer to sit for the deposition serves no purpose other than to harass and burden the company and disrupt the executive’s ability to meet their obligations integral to their position.

To the extent that information sought is privileged, Sheldon’s counsel will have an opportunity to object and get an immediate ruling from special master Judge Marx.

Sheldon’s objections to the document requests in the deposition notice were already addressed during the August 29, 2025 hearing and in an order dated September 16, 2024 (D.E.

Filing # 218270450 E-Filed 03/06/2025 05:00:32 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 Motion for Protective Order Regarding Subpoena and having reviewed the Motion and being fully advised in the premises, the Court hereby ORDERS and ADJUDGES

Judge Joseph Marx shall attend Ms. Hairston’s deposition in his capacity as Special Master.

Ms. Hairston shall not be required to pay the Special Master’s fees and costs related to her deposition

Ms. Hairston shall be given the opportunity to designate and she may designate any exhibit, deposition testimony, transcript, or video (“Deposition Material”) as Confidential pursuant to the Court’s June 8, 2024 Agreed and Amended Confidentiality Order.

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.

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.