`
`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.
`
`____________________________________________/
`
`
`
`PLAINTIFF’S SECOND REQUEST TO PRODUCE TO DEFENDANT
`
`Plaintiff, CHENEY BROS., INC.(“CBI”), by and through its undersigned attorneys,
`
`pursuant to Rule 1.350, Florida Rules of Civil Procedure, requests Defendant, WESLEY
`
`RICHARDS, to produce the following documents at the offices of the undersigned counsel for
`
`inspection and/or copying within the time specified by the aforementioned Rule and Rule
`
`1.090(e), Florida Rules of Civil Procedure, or at such other place and time as may be agreed
`
`NOT A CERTIFIED COPY
`
`upon by counsel:
`
`Definitions
`
`A.
`
`B.
`
`
`C.
`
`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
`
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 05/31/2023 02:13:18 PM ***
`
`
`
`(2) people or among more than two (2) people.
`
`CASE NO.: 2023-CA-001432
`
`Documents Requested
`Any and all correspondence between you and any head hunters/recruiters (2018-2023).
`Any and all correspondence between you and any prospective employers (2018-2023).
`
`1.
`
`2.
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-
`portal this 31st day of May, 2023, to: Beth Coke, Esq., Coke Employment Law, 131 N. 2nd
`Street,, Suite 204, Fort Pierce, FL 34950 (beth@cokeemploymentlaw.com).
`
`NOT A CERTIFIED COPY
`
`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
`
`2
`
`
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