`
`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.
`
`____________________________________________/
`
`
`NOT A CERTIFIED COPY
`
`NOTICE OF TAKING DEPOSITION DUCES TECUM
`
`PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition of:
`
`DEPONENT
`
`DATE
`
`TIME
`
`PLACE
`
`Wesley Richards
`
`Tuesday, July 18, 2023 10:00 a.m. Wyland & Tadros, LLP
`2505 Metrocentre Boulevard
`2nd Floor
`West Palm Beach, FL 33407
`
`
`
`
`
`
`
`
`The witness is directed to bring with them the documents outlined in Exhibit AAA@@
`attached hereto.
`
`upon oral examination before Lawyers’ Reporting, Notary Public or other office authorized by law
`to take depositions in the State of Florida. The oral examination will continue from day to day
`until completed. This deposition is being taken for purposes of discovery, for use at trial, or for
`such other purposes as are permitted under applicable Florida Rules of Civil Procedure.
`
`
`
`
`
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 06/23/2023 01:56:25 PM ***
`
`
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-portal
`this 23rd day of June, 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/Charles Andrew Tharp
`DAVID S. TADROS, ESQ.
`FBN 956015
`CHARLES ANDREW THARP, ESQ.
`FBN 0746134
`
`NOT A CERTIFIED COPY
`
`
`
`
`
`Exhibit A
`
`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`9.
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`10.
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`11.
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`12.
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`13.
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`14.
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`15.
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`16.
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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.
`
`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.
`
`Any and all documents concerning your severance from CBI.
`
`Any and all applications for employment with Presidential Aviation, Inc.
`
`Any and all documents provided to Presidential Aviation, Inc. regarding employment and
`as part of the employment application.
`
`Any and all correspondence with Presidential Aviation, Inc.
`
`Any and all documents exchange by you with Presidential Aviation, Inc.
`
`Any and all applications for employment for the years 2018 – 2023.
`
`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.
`
`Any and all copies of your current job description.
`
`
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`17.
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`18.
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`19.
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`20.
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`21.
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`22.
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`23.
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`24.
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`25.
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`26.
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`27.
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`28.
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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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`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.
`
`Any and all documents related to payment for certifications, licenses or other 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.
`
`Any and all Tax Returns with supporting documents for the years 2020-2022.
`
`A copy of your Pilot logbook.
`
`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).
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`Any and all correspondence between you and Thomas Allen.
`
`
`
` NOT A CERTIFIED COPY
`
`
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