Filing # 168496179 E-Filed 03/10/2023 02:37:37 PM
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`IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT,
`IN AND FOR PALM BEACH COUNTY, FLORIDA
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`CASE NO.: 2023-CA-001432
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`CHENEY BROS., INC.,
`a Florida Corporation,
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`Plaintiff,
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`vs.
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`WESLEY RICHARDS,
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`Defendant._INOTICE OF SERVICE OF INTERROGATORIES
`NOT A CERTIFIED COPY
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`Plaintiff, CHENEY BROS., INC., propounds the attached Interrogatories to Defendant,
`to be answered in accordance with Florida Rule of Civil Procedure
`WESLEY RICHARDS,
`
`1.340.
`
`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
`com
`
`BY:
`
`/s/David S. Tadros_
`
`DAVID S. TADROS, ESQ.
`FBN 956015
`CHARLES ANDREW THARP, ESQ.
`FBN 0746134
`
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/10/2023 02:37:37 PM ***
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`
`
`IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT,
`IN AND FOR PALM BEACH COUNTY, FLORIDA
`
`CASE NO.: 2023-CA-001432
`
`CHENEY BROS., INC.,
`a Florida Corporation,
`
`Plaintiff,
`
`vs.
`
`WESLEY RICHARDS,
`
`Defendant._INOTICE OF SERVICE OF INTERROGATORIES
`NOT A CERTIFIED COPY
`
`Plaintiff, CHENEY BROS., INC., propounds the attached Interrogatories to Defendant,
`to be answered in accordance with Florida Rule of Civil Procedure
`WESLEY RICHARDS,
`
`1.340.
`
`CERTIFICATE OF SERVICE
`
`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
`com
`
`BY:
`
`/s/David S. Tadros_
`
`DAVID S. TADROS, ESQ.
`FBN 956015
`CHARLES ANDREW THARP, ESQ.
`FBN 0746134
`
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/10/2023 02:37:37 PM ***
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`CASE NO.: 2023-CA-001432
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`INTERROGATORIES TO DEFENDANT
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`NOT A CERTIFIED COPY
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`What is the name and address of the person answering these interrogatories?
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`Please state the name of your current employer, including the name of your direct
`supervisor.
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`Please state your current job position and your job duties and responsibilities.
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`CASE NO.: 2023-CA-001432
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`Please state when you applied for your current job position.
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`Please state when you accepted your current job position.
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`state your compensation and any bonuses,
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`(health/life/disability) with your current employer.
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`NOT A CERTIFIED COPY
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`including all benefits
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`CASE NO.: 2023-CA-001432
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`Please list all training completed by you for certification in the Citation Sovereign and the
`time frame of the training.
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`Please state where you received training for certification to fly the Citation Sovereign.
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`Please state if you paid for the training for certification in the Citation Sovereign and the
`amount paid. If you did not pay for the training, please state who paid for the training.
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`NOT A CERTIFIED COPY
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`CASE NO.: 2023-CA-001432
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`Please state the date you severed your employment with Cheney Brothers, Inc. (“CBI”).
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`including all benefits
`state your compensation and any bonuses,
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`(health/life/disability) during your tenure with CBI. You may list your compensation for
`each year starting in 2018.
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`Please state your job duties and responsibilities during the last year of employment with
`CBI.
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`NOT A CERTIFIED COPY
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`CASE NO.: 2023-CA-001432
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`Please list any and all training paid for by CBI, including, but not limited to, licenses,
`certifications, continuing education or other training necessary for you to perform your
`job duties.
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`Please list all aircraft certifications and licenses you currently have.
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`Please list the names and addresses of all persons who are believed by or known by you,
`your agents, or your attorneys to have any knowledge concerning any of the issues in this
`lawsuit; and specify the subject matter about which the witness has knowledge.
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`NOT A CERTIFIED COPY
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`CASE NO.: 2023-CA-001432
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`Please list all persons interviewed with for a pilot position with Presidential Aviation,
`Inc. and include their full name, address and phone number.
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`Please state the date you first contacted anyone at Presidential Aviation, Inc. regarding a
`pilot position with the company.
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`Please list each communication you had with Presidential Aviation, Inc. and specify the
`person(s) communicated with, the form of communication (phone, meeting, email letter,
`video conference etc.) and the subject matter of the communication.
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`Please list any and all recruiters utilized to secure employment with Presidential
`Aviation, Inc.
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`CASE NO.: 2023-CA-001432
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`Please let your starting date of employment with Presidential Aviation, Inc.
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`NOT A CERTIFIED COPY
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`Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other
`than the present matter, and, if so, state whether you were plaintiff or defendant, the
`nature of the action, and the date and court in which such suit was filed.
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`CASE NO.: 2023-CA-001432
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`WESLEY RICHARDS
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`STATE OF FLORIDA
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`COUNTY OF
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`WESLEY RICHARDS, being duly sworn, deposes and says that the attached Answers to
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`Interrogatories are true and correct to the best of knowledge, information and belief. Sworn
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`to and subscribed before me this day of , 2023.
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`Notary Public-State of Florida
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`Print, Type or Stamp Name of
`Notary Public
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`NOT A CERTIFIED COPY
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` (
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` ) Personally known to me, or
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` ) Produced identification:
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`__________________________Type of identification
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