Filing # 178977418 E-Filed 08/04/2023 03:24:36 PM
`
`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 FIRST REQUESTS FOR ADMISSIONS TO DEFENDANT
`
`NOT A CERTIFIED COPY
`
`Plaintiff, CHENEY BROS., INC. (“CBI”), by and through its undersigned attorneys,
`
`pursuant to Rule 1.370, Florida Rules of Civil Procedure, requests the Defendant, WESLEY
`
`RICHARDS, to admit or deny the following Requests for Admissions, within thirty (30) days from
`
`the date of service.
`
`1.
`
`2.
`
`3.
`
`Admit that it was your intention to leave CBI if you did not receive a pay increase upon
`
`completion of training/certification for the Cessna Citation Sovereign 680.
`
`Admit that you communicated to your co-employees your intention to leave CBI if you did
`
`not receive a pay increase upon completion of training/certification for the Cessna Citation
`
`Sovereign 680.
`
`Admit that you communicated to Ivan Brenes your intention to leave CBI if you did not
`
`receive a pay increase upon completion of training/certification for the Cessna Citation
`
`Sovereign 680.
`
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 08/04/2023 03:24:36 PM ***
`
`
`
`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 FIRST REQUESTS FOR ADMISSIONS TO DEFENDANT
`
`NOT A CERTIFIED COPY
`
`Plaintiff, CHENEY BROS., INC. (“CBI”), by and through its undersigned attorneys,
`
`pursuant to Rule 1.370, Florida Rules of Civil Procedure, requests the Defendant, WESLEY
`
`RICHARDS, to admit or deny the following Requests for Admissions, within thirty (30) days from
`
`the date of service.
`
`1.
`
`2.
`
`3.
`
`Admit that it was your intention to leave CBI if you did not receive a pay increase upon
`
`completion of training/certification for the Cessna Citation Sovereign 680.
`
`Admit that you communicated to your co-employees your intention to leave CBI if you did
`
`not receive a pay increase upon completion of training/certification for the Cessna Citation
`
`Sovereign 680.
`
`Admit that you communicated to Ivan Brenes your intention to leave CBI if you did not
`
`receive a pay increase upon completion of training/certification for the Cessna Citation
`
`Sovereign 680.
`
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 08/04/2023 03:24:36 PM ***
`
`
`
`
`4.
`
`CASE NO.: 2023-CA-001432
`
`
`Admit that you communicated to Alex Ice your intention to leave CBI if you did not receive
`
`a pay increase upon completion of training/certification for the Cessna Citation Sovereign
`
`680.
`
`5.
`
`Admit that you communicated (phone, text, email, job board, person-to-person) with a
`
`recruiter or aviation company during the period of November 28, 2022 through December
`
`13, 2022 about available positions as a pilot (PIC or SIC).
`
`Admit that you communicated (phone, text, email, job board, person-to-person) with a
`
`recruiter or aviation company during the 90-day period prior to November 28, 2022 about
`
`available positions as a pilot (PIC or SIC).
`
`Admit that you communicated (phone, text, email, job board, person-to-person) with a
`
`recruiter or aviation company during the 30-day period after December 13, 2022 about
`
`available positions as a pilot (PIC or SIC).
`
`Admit that you were a member of the job board “Climbto350” during the period of
`
`November 28, 2022 through December 13. 2022.
`
`Admit that you were a member of the job board “Climbto350” during the 90-day period
`
`prior to November 28, 2022.
`
`Admit that you were a member of the job board “Climbto350” during the 30-day period
`
`NOT A CERTIFIED COPY
`
`after December 13, 2022.
`
`Admit that you contacted Presidential Aviation through the job board “Climbto350.”
`
`Admit that you contacted Thomas Allen through the job board “Climbto350.”
`
`Admit that you communicated (phone, text, email, job board, person-to-person) with
`
`Thomas Allen during the period of November 28, 2022 through December 13, 2022.
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`2
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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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`CASE NO.: 2023-CA-001432
`
`
`Admit that you communicated (phone, text, email, job board, person-to-person) with
`
`Thomas Allen during the 90-day period prior to November 28, 2022.
`
`15.
`
`Admit that you communicated (phone, text, email, job board, person-to-person) with
`
`Thomas Allen during the 30-day period after December 13, 2022.
`
`Admit that you communicated (phone, text, email, job board, person-to-person) with a
`
`representative of Presidential Aviation during the period of November 28, 2022 through
`
`December 13, 2022.
`
`Admit that you communicated (via phone, text, email, job board, person-to-person) with a
`
`representative of Presidential Aviation during the 90-day period prior to November 28,
`
`NOT A CERTIFIED COPY
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`2022.
`
`Admit that you communicated (phone, text, email, job board, person-to-person) with a
`
`representative of Presidential Aviation during the 30-day period after December 13, 2022.
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`Admit that you communicated (phone, text, email, job board, person-to-person) with a
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`representative of Premier Aviation during the period of November 28, 2022 through
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`December 13, 2022.
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`Admit that you communicated (phone, text, email, job board, person-to-person) with a
`
`representative of Premier Aviation during the 90-day period prior to November 28, 2022.
`
`Admit that you communicated (phone, text, email, job board, person-to-person) with a
`
`representative of Premier Aviation during the 30-day period after December 13, 2022.
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`Admit that you communicated (phone, text, email, job board, web page, person-to-person)
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`with a representative of NetJets during the period of November 28, 2022 through December
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`13, 2022.
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`3
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`16.
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`17.
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`18.
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`20.
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`21.
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`22.
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`23.
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`CASE NO.: 2023-CA-001432
`
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`Admit that you communicated (phone, text, email, job board, web page, person-to-person)
`
`with a representative of NetJets during the 90-day period prior to November 28, 2022.
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`24.
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`Admit that you communicated (phone, text, email, job board, web page, person-to-person)
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`with a representative of NetJets during the 30-day period after December 13, 2022.
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`Admit that you communicated (phone, text, email, person-to-person) with co-employees
`
`at CBI during the period of November 28, 2022 through December 13, 2022 about your
`
`efforts to obtain a pilot position (PIC or SIC) with another company.
`
`Admit that you communicated (phone, text, email, person-to-person) with co-employees
`
`at CBI during the 90-day period prior to November 28, 2022 about your efforts to obtain a
`
`pilot position (PIC or SIC) with another company.
`
`Admit that you communicated (phone, text, email, person-to-person) with co-employees
`
`at CBI during the 30-day period after December 13, 2022 about your efforts to obtain a
`
`pilot position (PIC or SIC) with another company.
`
`Admit that you communicated (phone, text, email, person-to-person) with Ivan Brenes
`
`during the period of October 28, 2022 through December 13, 2022 about your efforts to
`
`obtain a pilot (PIC or SIC) with another company.
`
`Admit that you communicated (phone, text, email, person-to-person) with Ivan Brenes
`
`during the 90-day period prior to November 28, 2022 about your efforts to obtain a pilot
`
`NOT A CERTIFIED COPY
`
`position (PIC or SIC) with another company.
`
`Admit that you communicated (phone, text, email, person-to-person) with Ivan Brenes
`
`during the 30-day period after December 13, 2022 about your efforts to obtain a pilot
`
`position (PIC or SIC) with another company.
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`4
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`25.
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`27.
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`28.
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`29.
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`30.
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`CASE NO.: 2023-CA-001432
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`31.
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`32.
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`33.
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`Admit that you communicated (phone, text, email, person-to-person) with Alex Ice during
`the period of October 28, 2022 through December 13, 2022 about your efforts to obtain a
`pilot (PIC or SIC) with another company.
`Admit that you communicated (phone, text, email, person-to-person) with Alex Ice during
`the 90-day period prior to November 28, 2022 about your efforts to obtain a pilot position
`(PIC or SIC) with another company.
`Admit that you communicated (phone, text, email, person-to-person) with Alex Ice during
`the 30-day period after December 13, 2022 about your efforts to obtain a pilot position
`(PIC or SIC) with another company.
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-portal
`this 4th day ofAugust, 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/Charles Andrew Tharp_
`
`DAVID S. TADROS, ESQ.
`FBN 956015
`CHARLES ANDREW THARP, ESQ.
`FBN 0746134
`
`5
`
`
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