Filing# 144159755 E-Filed 02/17/2022 05:37:21 PM
`
`GREGORY SULLIVAN and JANET
`SULLIVAN, his wife,
`
`Plaintiffs,
`
`VS.
`
`AIR & LIQUID SYSTEMS
`CORPORATION, et al.,
`
`Defendants.
`
`'
`
`IN THE CIRCUIT COURT OF THE 17,TH
`JUDICIAL CIRCUIT IN AND FOR
`BROWARD COUNTY, FLORIDA
`
`CASE NO. 21-012069-CA-27
`
`NON-PARTY MOSAIC GLOBAL OPERATIONS, INC.'S
`OBJECTIONS TO PLAINTIFF'S SUBPOENA DUCES TECUM, AND
`MOTION FOR PROTECTIVE ORDER AND MOTION TO ENFORCE
`A STIPULATED CONFIDENTIALITY AND NON-DISCLOSURE AGREEMENT
`
`Defendant, MOSAIC GLOBAL OPERATIONS, INC ("Mosaic"), through its
`
`undersigned counsel, serves objections,moves for an Order protectingit from a Subpoena
`
`Duces Tecum for Production of Documents Without Depositionserved on or about February 1,
`
`2022, and moves to enforce a StipulatedConfidentialityand Non-Disclosure Agreement filed
`
`with this Court on November 14, 2016 in the matter of Robert L. Schmidt v. Ameron
`
`International Corp.,et al,Case No. 15-CA-010245, Div. Z, HillsboroughCounty, Florida. In
`
`support, Mosaic states as follows:
`
`1
`
`Mosaic is a foreign corporationwith its principalplace outside the State of
`
`Florida. Mosaic has, throughmergers and acquisitions,developed ownership interests in certain
`
`industrial plants located in the State of Florida, including a plant called "New Wales" in
`
`Mulberry, Florida. For a periodof time, the plaintiffin this asbestos personalinjurycase worked
`
`at the New Wales plant. Mosaic also has ownership interests in other plantsnear Mulberry,
`
`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/17/2022 05:37:21 PM.****
`
`

`

`Florida but, upon Mosaic's information and belief,the plaintiffnever worked at any of these
`
`other plants. Some of these plantshave been in operationfor decades and are still in operation,
`
`while others were once in operationfor many years but have in recent years been idle(d).
`
`2.
`
`Mosaic is not a party to this personalinjurylawsuit,nor could it ever become a
`
`party by virtue of the immunities afforded to it under Chapter 440, Florida Statutes.
`
`3
`
`On or about February 1, 2022, Plaintiff served a subpoena duces tecum upon
`
`Mosaic's registeredagent that asks Mosaic to produce the following:
`
`a.
`
`b
`
`C
`
`Documents related in any way to the sale,purchase, acquisition,
`supply, distribution,installation,repair, maintenance, and/or
`removal of Bondstrand pipe at any of your facilities located within
`10 miles of Mulberry, Florida.
`Documents related in any way to any transactions with Mineco,
`Inc.
`An Affidavit of Record authenticatingthe documents produced.
`
`See Exhibit "A," Subpoena to Mosaic.
`
`4.
`
`Mosaic retained undersigned counsel to assist with responding to the subpoena.
`
`Undersigned counsel has had several discussions with plaintiff'scounsel (Ms. Carsten) about
`
`the scope of the subpoena and that an extension of time of approximately 90 days would be
`
`needed in order for Mosaic to conduct the tasks necessary to respond to the subpoena, but so
`
`far those discussions have not resulted in any formal agreement.
`
`5.
`
`Nevertheless, during these discussions,undersigned counsel was advised that
`
`plaintiff'scounsel had just obtained (from a yet-unknown source) copies of a very large
`
`confidential document productionby Mosaic in the unrelated, since-settled case of Robert L.
`
`Schmidt v. Ameron International Corp.,et al,Case No. 15-CA-010245, Div. Z, Hillsborough
`
`County, Florida.
`
`Mosaic's document production included (among many other things)
`
`Mosaic' s records from the New Wales plant.Apparently,after some motion practiceand after
`
`2
`
`

`

`the partieshad agreed to and signed a confidentialityagreement, the documents in that case
`
`were made available for review and copying by plaintiff(usingtheir copy service).
`
`6.
`
`Undersigned counsel was not involved in that prior lawsuit,but one of the
`
`plaintiff'sattorneys in this case, Rebecca Vinocur, Esq.,was also one of plaintiff'sattorneys in
`
`the Robert L. Schmidt case. Upon learning that plaintiff'scounsel (Ms. Carsten) was in
`
`possessionof the documents from the Robert Schmidt matter, undersigned counsel questioned
`
`whether a confidentialityagreement would have covered those documents, to which Ms.
`
`Carsten acknowledged there was a confidentialityagreement in place (how could she not-her
`
`co-counsel in this case, Ms. Vinocur, was named under the signatureblock on that Stipulated
`
`ConfidentialityAgreement) but contended that since none of the documents were individually
`
`marked "confidential,"plaintiffbelieved none of the documents were considered confidential.
`
`Plaintiff's counsel (Ms. Carsten) then suggestedthat,in lieu of Mosaic responding to the
`
`pending subpoena duces tecum served on February 2,2022, plaintiffwould instead accept an
`
`"affidavit" of a Mosaic records custodian attestingto the authenticityof the 27,000+ page
`
`document productionfrom the Robert Schmidt case.
`
`7.
`
`The problem, however, is that the 27,000+ page document production in the
`
`Robert Schmidt case was indeed confidential. Upon information and belief of Mosaic,
`
`1
`
`plaintiff'scounsel in the Robert Schmidt case received notification in writing specifically
`
`identifyingthe document production materials as "confidential,"which was an express and
`
`agreed-upon alternative to marking every page as "confidential."
`
`See Stipulated
`
`ConfidentialityAnd Non-Disclosure Agreement, attached hereto as Exhibit "B," 72 (option
`
`"ii").And because the materials were designatedconfidential,all such designateddocuments
`
`1
`
`Mosaic has made attempts to obtain copies of the written notices from its counsel in the Robert Schmidt
`case, Thomas Brink, Esq., but as of the filingof this motion has been unable to make contact with Mr. Brink.
`
`

`

`were not to be disseminated to anyone outside the litigation,see id. 73, and they were
`
`supposed to be destroyed or returned at the end of that case. See id.,710. Evidently,they
`
`were not all returned and destroyed. Plaintiff's counsel kept them, and as this case proves,
`
`freely disseminated them as well, in clear violation of the StipulatedConfidentiality
`
`Agreement.
`
`8
`
`Mosaic now must ask the court to enforce the StipulatedConfidentialityand
`
`Non-Disclosure Agreement, and hereby requests that this court Order the following:
`
`a. The immediate return of every singlecopy of every singledocument in the
`
`possessionof Ms. Carsten (and her firm) and Ms. Vinocur (and her firm)
`
`that was part of Mosaic's document productionin the Robert Schmidt case;
`
`and
`
`b. A list from plaintiff'scounsel of all persons, firms and partiesto whom the
`
`Mosaic document production,or any portionthereof,in the Robert Schmidt
`
`case was/were distributed (the"distribution list");and
`
`c. A certification from plaintiff'scounsel that all copies of these documents
`
`were returned, and that any electronic copies of these documents were
`
`permanently deleted from any folder, hard
`
`drive
`
`or cloud-storage
`
`mechanism; and
`
`d. A certification from plaintiff'scounsel that they know of no other persons,
`
`firms and parties,other than those identified in the distribution list,that
`
`were recipientsof the productionor any portionthereof.2
`
`Attempts at contact will continue and Mosaic will update the court on this issue at or before a hearing on this
`motion.
`2
`
`Mosaic will prepare the certifications for plaintiffssignatureonce this court agrees that such a certification
`is appropriate.
`
`4
`
`

`

`***
`
`9-
`
`Getting back to subpoena at issue which is still pending and which is the
`
`genesis of Mosaic's involvement here, Mosaic gives notice of the following objectionsand
`
`motion for protectiveorder as a precautionin the event no agreement is ever reached between
`
`Mosaic and plaintiff'scounsel concerning the scope or timing of a response.
`
`Obiections
`
`Mosaic first objectsto the request phrased as "[D]ocuments related in any way to ..."
`
`as that phrase is overly broad and incapableof any objectivedefinition. Whether a document
`
`"
`is "related" to a subject,includingsubjectsas broad as "sale" or "supply"or "distribution" of
`
`1 , ,
`
`..
`
`,,
`
`an item is potentiallyinfinite,but clearlysubjectto interpretation.Someone at Mosaic would
`
`have to make a judgment call on the "relatedness" of a document, and that is a burden Mosaic
`
`should not shoulder. Mosaic contends the subpoena should be narrowed to use a phrasewith
`
`more definition,such as "documents that state..." or "documents that contain .-..
`
`"
`
`Mosaic next objectsto the request for documents from plants that Plaintiff never
`
`worked at, meaning anywhere other than the New Wales plant. Documents pertainingto
`
`industrial sites that Plaintiff never worked at (and thus would have no exposures at)simply
`
`have no relevance to the claims in his asbestos case.
`
`Mosaic next objectsto the timing of the production(15 days) because it is technically
`
`not possible to respond to such a broad subpoena within the few days afforded by the
`
`subpoena. Indeed, the subpoena requiresMosaic to cull through potentiallythousands of
`
`pages of documents to determine whether they potentiallyapply to the subjectsof Bondstrand
`
`pipe or Mineco, Inc. Mosaic has asked plaintiff'scounsel for an agreement to at least 90 days
`
`to complete this task,and Mosaic now asks the court for the same time frame.
`
`

`

`Mosaic next objects to the request asking for Mosaic to supply an affidavit of a
`
`custodian, which in essence asks Mosaic to prepare a new document and then produce it to
`
`plaintiff'scounsel. There is nothing in the Florida Rules of Civil Procedure that requirea
`
`party or non-party to create such a document, and Mosaic is not volunteeringto do that in this
`
`case.
`
`Motion for Protective Order
`
`In accordance with the above, and again as a precautionin the event no agreements are
`
`reached between Mosaic and plaintiffon the subjectsof the subpoena, Mosaic moves for an
`
`Order protectingit from the February 2,2022 subpoena until such time as this motion is heard,
`
`and Mosaic also moves for an Order of protectionagainstthe improper copying,dissemination
`
`and use by others of records produced in the Robert Schmidt case that Mosaic believes and
`
`contends are subjectto confidentialityand return/destroyrequirements.
`
`WHEREFORE, Mosaic Global Operations requests this Court enter the relief
`
`requestedherein,along with such other relief deemed justand proper under the circumstances.
`
`SHAPIRO BLASI WASSERMAN & HERMANN PA
`Attorneysfor Mosaic Global
`Corporate Centre at Boca Raton
`7777 Glades Road, Suite 400
`Boca Raton, Florida 33434
`T: (561)477-7800 IlF: (561)477-7722
`sweinstein@sbwh.law
`lwood@sbwh.law
`
`By:
`
`/s/ Stuart A. Weinstein
`Stuart A. Weinstein, Esq.
`Florida Bar No. 0526630
`
`6
`
`

`

`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true and correct copy of the foregoingwas electronically
`
`served on all counsel of record via LexisNexis File and Serve this day of February 17,2022.
`
`By:
`
`/s/ Stuart A. Weinstein
`Stuart A. Weinstein, Esq.
`Florida Bar No. 0526630
`
`

`

`EXHIBIT "A ,,
`EXHIBIT “A”
`
`

`

`TRUE COPY
`SERVED
`DATE: CR/OI/Zraz
`TIME: IOL.WOAM
`ID#.71-821645
`IN THE CIRCUIT COURT OF THE 177[h
`JUDICIAL CIRCUIT IN AND FOR
`BROWARD COUNTY, FLORIDA
`
`ASBESTOS LITIGATION
`CASE NO. 21-012069 ca 27
`
`GREGORY SULLIVAN and JANET
`SULLIVAN, his wife,
`
`Plaintiffs,
`
`V.
`
`AIR & LIQUID SYSTEMS
`CORPORATION, et al.,
`
`Defendants.
`
`SUBPOENA DUCES TECUM FOR TH-E PRODUCTION OF DOCUMENTS WIIHOUT
`DEPOSITION PURSUANT TO FLA.R.CIV.P. 1.351(b)
`(YOU MAY MAIL THESE RECORDS IN LIEU OF APPEARANCE)
`THE STATE OF FLORIDA:
`
`TO:
`
`Record Custodian
`
`Mosaic Global Operations,Inc.
`101 East Kennedy BLVD
`STE 2500
`Tampa, FL 33602
`YOU ARE HEREBY COMMANDED to appear at the law office of Rebecca S. Vinocur,
`P.A. located at 5915 Ponce De Leon Blvd., Suite 14.,Coral Gables,FL 33146 within fifteen (15)
`days of service,and to have with you at that time and placethe following:
`Please see the attached "Schedule A"
`
`These items will be inspectedand may be copied at that time. You will not be requiredto
`surrender the originalitems. You may comply with this subpoena by providinglegiblecopiesof
`the items to be produced to the attorneywhose name appears on the subpoena on or before the
`scheduled date of production.You have the rightto objectto the productionpursuant to this
`subpoena at any time before productionby givingwritten notice to the attorney whose name
`appears on this subpoena.
`
`If you fail to:
`
`(1)
`
`(2)
`
`appear as specified,or
`
`objectto this subpoena
`
`

`

`you may be in contempt of court. You are subpoenaed by the attorneys whose name appears on
`this subpoena and, unless excused from the subpoena by the attorneys or the court, you shall
`respond to this subpoena as directed.
`
`/s/Rebecca S. Vinocur
`REBECCA S. VINOCUR
`Florida Bar No.: 529915
`REBECCA S. VINOCUR, P.A.
`5915 Ponce De Leon Blvd.,Suite 14
`Coral Gables, FL 33146
`Phone: 786.691.1282
`Fax: 786.691.1283
`
`/s/ J. Andrew Sealev
`J. ANDREW SEALEY
`Florida Bar No.: 52857
`SIMMONS HANLY CONROY
`One Court Street
`Alton, IL 62002
`Phone: 618.259.2222
`Fax: 618.259.2251
`
`com
`
`

`

`SCHEDULE A
`"Plaintiffs" means GREGORY SULLIVAN AND JANET SULLIVAN, Social SecurityNumber
`XXX-XX-2140, year ofbirth 1950.
`
`Document Requests
`
`Documents related in any way to the sale,purchase, acquisition,supply,distribution,
`1.
`installation,repair,maintenance, and/or removal of Bondstrand pipe at any ofyour facilities
`located within 10 miles of Mulberry, Florida.
`
`2,
`
`3.
`
`Documents related in any way to any transactions with Mineco, Inc.
`
`An Affidavit of Record authenticatingthe documents produced.
`
`Records subpoenaed and produced should be all inclusive and production should in no
`way be limited.
`
`Please contact this office concerning costs priorto copies of any and all records.
`
`/s/Rebecca S. Vinocur
`REBECCA S. VINOCUR
`Florida Bar No.: 529915
`REBECCA S. VINOCUR, P.A.
`5915 Ponce De Leon Blvd., Suite 14
`Coral Gables, FL 33146
`Phone: 786.691.1282
`Fax: 786.691.1283
`rvinocur@rsv-law.corn
`
`lit-J.Andrew Sgalel
`J. ANDREW SEALEY
`Florida Bar No.: 52857
`SIMMONS HANLY CONROY
`One Court Street
`Alton, IL 62002
`Phone: 618.259.2222
`Fax: 618.259.2251
`dsealey@simmonsfilirm. com
`
`

`

`EXHIBIT 66B ,,
`EXHIBIT “B”
`
`

`

`59829202
`Nov 14 2016
`
`02:05PM????
`
`ZZ-XM
`
`Filing# 48841386 E-Filed 1 1/14/2016 12:29:01 PM
`
`IN THE CIRCUIT COURT OF THE
`13th JUDICIAL CIRCUIT, IN AND
`FOR HILLSBOROUGH COUNTY,
`FLORIDA
`
`GENERAL JURISDICTION DIVISION
`
`CASE NO.: 15-CA-010245 Div, Z
`
`ROBERT L. SCHMIDT,
`
`Plaintiff,
`
`VS.
`
`AMERON INTERNATIONAL CORP., MOSAIC
`GLOBAL OPERATIONS INC., et al.,
`
`Defendanls.
`
`1
`
`STWULATEI) CONFIDENTIALrrY ANDNONDISCLOSURE AGREEMENT
`
`It is stipulatedanc! agreed by the midersignedattorneys, counsel for Defendant Mosaic
`
`Global Operations,Inc. and counsel for Plaintiff,as follows:
`
`1.
`
`Sgone. Defendant/Mosaic Global Operations Inc. may designateas "Confidential" all or
`
`any part of the following discovery material received on or after November 14. 2016: (i)
`
`documents produced by counsel for Defendant/Mosaic Global Operations Inc, or made available
`
`ior inspeetionby counsel for Delb,idam/Mosaic Global Operations Inc.; and (ii)any other
`
`information produced by Mosaic Global Operations Inc. or disclosed hy Mosaic Global,
`
`OperationsInc. diiring the course of this litigation.Defendant shall make the designation of
`
`"Confidential" material after a good faith detet mitiation thut the motel ial constitutes a trade
`
`secret, proprietarybusiness or financial infot mation, or other confidential research, developnient.
`
`or commercial int'orriiation.
`
`Page 1
`
`

`

`2.
`
`Designation of Confidential Material. The designation of material as "Confidential" shall
`
`be macie either (i)by stamping or otherwise marking such materials "CONFIDENTIAL", or the
`
`equivalent,in a manner such that the legend is capable of beingreproduced in the normal process
`
`of photocopying and will not interi'ere with the legibilityof the document or (ii)by notityiiig
`
`counsel of record for the partiesin writingspecificallyidentifyingthe material to be designated
`
`as "Confidential."
`
`3.
`
`Restrictions on Use of ConfidentiallyDesignated Matgria[, Material designated
`
`"confidential" shall be used and disclosed solely for the prosecution or defense of the claims in
`
`or relatingto the instant litigationand any appeal thereof and shall not be used or disclosed in
`
`any other pending litigationor future litigationor business or commercial or competitive or
`
`personal or other purpose.
`
`4
`
`"
`Access to "Confidential" Materials. Discovery materials designated "Confidential" shall
`
`be maintained in confidence by the party to whom such materials are produced or disclosed
`
`solelyfor use as provided iii paragraph 3 of this Order and shall not be disclosed to any person
`
`except:
`
`This Court and its officers:
`
`b.
`
`e.
`
`d.
`
`e.
`
`Counsel of record and employees of counsel of recoid;
`
`Deponents during the takingoftheil depositionin this litigation.
`
`Expert witnesses as retained by counsel of record;
`
`Other persons as ordered by the Court; and
`
`Principalsof the partiesinvolved in the litigation.
`
`5,
`
`Copies and Summaries. Any person who obtains access to material designated as
`
`"Confidential" under this StipulatedProtective Order shal I not make copies, abstracts, extracts,
`
`Page 2
`
`

`

`analyses, summaries, or other materials which contain, reflect
`
`or
`
`disclose
`
`confidential
`
`information, except for use in this litigation,and each such copy, abstract, extract, analysis,
`
`su Inmary, or other material which contains, reflects or discloses confidential information, is to be
`
`treated in accordance with the provisionsof this StipulatedProtective Order. This provision does
`
`not include Attorney Work Product or Attorney-ClientPrivilegeddocumentation, All copies of
`
`material stamped "Confidential" in accordance with Paragraph 2 of this Order shall again be
`
`stamped with the respective designationif the originalstamp was not reproduced in the
`
`duplicatingprocess.
`
`6.
`
`Filing Confidential Material. No "Confidential" material shall be filed in the public
`
`record of this action. All material so designated in accordance with the terms of this Stipulated
`
`Protective Order that is filed with this Court, and any pleadings,motions or other papers
`
`containingconfidential material, shall be filed in a sealed envelope and kept under seal by the
`
`Clerk of this Court until further order of this Court. Where possible,only confidential portions
`
`of filingswith this Court shall be filed under seal, To facilitate compliance with this Order by the
`
`Clerk's office, material filed imder the designation "Confidential" shall be contained in a sealed
`
`envelope bearing such designation on its front face. In addition, the envelope shall bear the
`
`caption ofthe case, shall contain a concise, non-disclosing inventoryof its contents for docketing
`
`purposes, and shall state thereon that it is filed under the terms of this StipulatedProtective
`
`Order,
`
`7.
`
`All "Conlldentia]" information produced by a
`Maijitejianse o.f-?Cuufidenliti!.M?{ikdpl.
`
`party shall be stored imder the direct control of colmsel of record who shall be responsiblefor
`
`preventing any disclosure thereof, except in accordance with the terms of this Sliplilated
`
`Protective Order,
`
`Page 3
`
`

`

`8.
`
`Request for Diselosurg.pf Confidential Malprigls iii Anotlicrfrpcecding,If Plaintiff
`
`or his counsel is requested or required (by oral questions,interi ogatories,requests for
`
`information or documents, subpoena, civil investigativedemand, or other process or otherwise in
`
`connection with any investigationor litigation)to disclose any confidential material produced by
`
`Defendant hereto, Plaintiff or his counsel will provideto Defendant prompt notice of any such
`
`request or requirement,unless otherwise prohibitedby law.
`
`9.
`
`Additional Protective Orders, This Order shall be without prejudicelo the rightof the
`
`partiesto present a motion to the Court foi a separate protectiveorder as to any particular
`
`document or information, includingrestrictions differingfrom those as specifiedherein. This
`
`StipulatedProtective Order shall not be deemed to prejudicethe partiesin any way in any future
`
`applicationfor modification of this StipulatedProtective Order.
`
`10.
`
`Uisgg.sitionof Cgqfklgllia-LMji-tqrjilj.Aftg
`ihc Case. Upon final adjudication,or
`
`resolution through settlement,of this action,Plaintiff or his counsel shall assemble and return to
`
`Defendant al] documents, materials, and depositiontranscriptsdesignatedas confidential
`
`material and all copies of same, or shall certifythe destruction thereof, This section is subjectto
`
`any subsequent agreement amongst the parties,or any orders by the Court pursuant to Paragraph
`
`9 above.
`
`11,
`
`Submission to the Court. The partiesagree to submit this Stipulatcd Protective Order for
`
`entry to the Court. The partiesagree to be bound by its terms for disputesarisingafter
`
`submission to the Court and subsequent to entry by the Court,
`
`12.
`
`No Waiver p f Rigbti. f liisStipulatcdProtective Order shall not be deemed a waiver of:
`
`a,
`
`b.
`
`Any party'srightlo objectto any discoveryreciuestson any ground;
`
`Any party's rightto seek an oider compellingdiscovery with respect to any
`
`Page 4
`
`

`

`discoveryrequest;
`
`C.
`
`d.
`
`Any party's rightto use its own documents with completediscretion;or
`
`Any party's right t() move the Court to amend any portion of this Stipulated
`
`Protective Order.
`
`13.
`
`Dufatjon. This Order shall szirvive the final termination of this action, to the extent that
`
`the information contained in "Confidential" material is not or does not become known to the
`
`public other than in breach of the terms of the StipulatedPi olective Order, and the Court shall
`
`retain jurisdictionto resolve any disputeconcerningthe use of information disclosed hereunder.
`
`At the conclusion of this litigationall documents produced by Defendant/Mosaic Global
`
`Operations Inc. and all copies thereof slial] be destroyed or returned to counsel for the
`
`Defendant.
`
`14.
`
`The undersigned partiesagree that counsel for the parties shall be required to execute this
`
`agreement and be bound to this Protective Order priorto receivingany "Confidential" materials,
`
`ii.K
`Entered into and agreed between the parties this-//ff- day of ?+DO:,eil--- ?,
`
`2016.
`
`Bridget B, T?ixillo,Esquire
`Rebecca S. Vinocur, Esquire
`Florida Bar No. 0529915
`Rebecca S. Vine)cur,P.A,
`5915 Ponce De Leon Blvd.
`Suite 11
`Coral Gables, Florida 33146
`Telephone: (786) 691-1282
`Facsimile: (786) 691-1280
`Counsel for Plaintiff
`
`F..C@..7-.6-
`f Thomas F. Brink, Esquire
`Florida Bar No. 0467642
`Litchfield Cavo LLP
`5201 West Kennedy Boulevard
`Suite 450
`Tampa, Florida 33609
`(813) 289-0690
`(8 I 3) 289-()692
`Counsel for Defendant Mosaic Global
`Operations, Inc.
`
`,
`
`Page 5
`
`

`

`IN THE CIRCUIT COURT OF THE
`13th JUDICIAL CIRCUIT, IN AND
`FOR HILLSBOROUGH COUNTY,
`FLORIDA
`
`GENERAL JURISDICTION DIVISION
`
`CASE NO.: 15-CA-010245 Div. Z
`
`ROBERT L. SCHMIDT,
`
`VS.
`
`Plaintiff,
`
`AMERON INTERNATIONAL CORP., MOSAIC
`GLOBAL OPERATIONS INC., et al.,
`Defendants.
`
`i
`
`ORDER ON DEFENDANT MOSAIC GLOBAL OPERATIONS INC.'S
`STIPULATED AND NONDISCLOSURE AGREEMENT
`
`This Court, having reviewed the Court file, having received the STIPULATED
`
`CONFIDENTIALITY AND NONDISCLOSURE AGREEMENT, and the Court being otherwise
`
`duly advised, it is hereby ORDERED AND ADJUDGED:
`
`1.
`
`Plaintiff and Defendant Mosaic Global have agreed to enter into the "Stipulated
`
`Confidentialityand Nondisclosure Agreement."
`
`2.
`
`Plaintiff and Defendant Mosaic
`
`Global
`
`shall
`
`adhere
`
`to
`
`the
`
`"Stipulated
`
`Confidentialityand Nondisclosure Agreement" in all matters outlined therein.
`
`DONE AND ORDERED in Chambers at Hillsborough County, Florida on this
`
`day
`
`of
`
`cc:
`
`,2016.
`
`Bridget B. Truxillo, Esq.
`Rebecca S. Vinocur, Esq.
`Thomas F. Brink, Esq.
`
`Circuit Court Judge
`
`