News Reedy Creek Improvement District and the Central Florida Tourism Oversight District

Rhinocerous

Premium Member
And here we go. CFTOD requesting docs from TWDC and scheduling depositions.
I have no experience with these type of requests. Is it common to be able to mandate that documents be provided in multiple formats and that that everything be rendered searchable in their database? Seems to me that the onus to OCR everything should be on the requester.

Also, they appear to be casting an extraordinarily wide net. I’m sure they hope to find something damning by asking for literally anything related to DeSantis and the various instances of legislative retribution which have occurred recently, but I can’t fathom what that could be. Even if Bob Chapek sent a memo saying “I hate Ron DeSantis because I’m jealous of him so we’re going to torpedo his very brave and righteous bill” that doesn’t legitimize the retaliation that followed. What are they hoping to find?
 

JoeCamel

Well-Known Member
I have no experience with these type of requests. Is it common to be able to mandate that documents be provided in multiple formats and that that everything be rendered searchable in their database? Seems to me that the onus to OCR everything should be on the requester.

Also, they appear to be casting an extraordinarily wide net. I’m sure they hope to find something damning by asking for literally anything related to DeSantis and the various instances of legislative retribution which have occurred recently, but I can’t fathom what that could be. Even if Bob Chapek sent a memo saying “I hate Ron DeSantis because I’m jealous of him so we’re going to torpedo his very brave and righteous bill” that doesn’t legitimize the retaliation that followed. What are they hoping to find?
This is tit for tat to answer the documents request Disney made. Same claims of overbroad, many formats, burdensome etc. Much of law has become about the show....
 

UNCgolf

Well-Known Member
I have no experience with these type of requests. Is it common to be able to mandate that documents be provided in multiple formats and that that everything be rendered searchable in their database? Seems to me that the onus to OCR everything should be on the requester.

Also, they appear to be casting an extraordinarily wide net. I’m sure they hope to find something damning by asking for literally anything related to DeSantis and the various instances of legislative retribution which have occurred recently, but I can’t fathom what that could be. Even if Bob Chapek sent a memo saying “I hate Ron DeSantis because I’m jealous of him so we’re going to torpedo his very brave and righteous bill” that doesn’t legitimize the retaliation that followed. What are they hoping to find?

I haven't read their request, but as someone who deals with ediscovery in large corporate litigation, we typically provide documents in TIFF format along with a TXT file of the extracted text (which is obviously searchable) and a load file with metadata. We also usually provide Excels natively, along with some other less common files like videos or audio. That's more or less standard practice in corporate litigation.

Sometimes productions are done entirely as PDFs (again other than native Excels) but that's not regular practice.

I also do a lot of government investigation work, and it's very similar. Some government departments/commissions require native production of PowerPoints along with Excels, and they often have some other specific requirements, but it's still generally TIFF/extracted text TXT file/metadata.

EDIT: I just skimmed through the document request and it's not really out of the ordinary. They are requesting native PowerPoints, but while that's less common, it's certainly not unheard of. The privilege log request is pretty standard too.
 
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Isamar

Well-Known Member
And here we go. CFTOD requesting docs from TWDC and scheduling depositions.

There are some lawyers on that list, so I expect there’ll be strong disagreements (and possibly litigation) about the appropriate limits on deposition questions.

At least the district seems to have abandoned their attempt to avoid full discovery.
 

DCBaker

Premium Member
Update from the Orlando Sentinel on the cash stipend as a replacement for park passes/discounts for district firefighters.

"Unionized firefighters are waiting to receive cash stipends to make up for Disney perks ended by Gov. Ron DeSantis’ tourism oversight district.

About 200 unionized employees – more than half of the district’s workforce – haven’t gotten the $3,000 stipend because of a disagreement with the district over the benefit’s value, said Jon Shirey, president of the district’s firefighters union.

“We have had one bargaining session over the stipend, but it went nowhere,” he said.

The deadlock comes as administrator Glen Gilzean touts increased employee morale at the Central Florida Tourism Oversight District made possible through his “open door” policy and additional benefits. More than 40 of the district’s roughly 370 employees have resigned or retired since the state seized control in February.

The district’s board approved the stipend at their meeting in September.

“Under the current contract, the district cannot provide additional benefits without renegotiating the contract,” said Alexei Woltornist, a district spokesman. “Contract negotiations are currently underway, and we cannot comment further at this time.”

Union officials estimated the value of the Disney passes and discounts to be at least $5,000. The Disney perks program covered theme park entry for employees, their spouses and three guests, an employee familiar with the benefit said. The program also included discounts at Disney restaurants and hotels.

DeSantis’ hand-picked tourism oversight board took aim at the perk, calling it an “unethical” arrangement that exclusively benefited Disney over other businesses. But the board faced a backlash from some employees who said the theme park passes were a key factor in their decision to work there.

At this month’s meeting, Gilzean said employees would get two additional paid holidays — Veterans Day and the day before Thanksgiving — when outlining his efforts to boost employee morale. Those days are also subject to bargaining, so union members aren’t presently eligible for those paid holidays, Shirey said.

The Reedy Creek Professional Firefighters, the union led by Shirey, endorsed DeSantis’ re-election bid with the district’s future still in question. Formerly known as Reedy Creek, the Central Florida Tourism Oversight District provides fire protection and other government services to Disney World.

Union officials praised DeSantis when he appointed the new board earlier this year. Shirey accused the previous Disney-friendly board and management of neglecting public safety by not addressing staffing and equipment shortages.

The new administration approved a union contract in July, ending about five years of negotiations and answering the governor’s calls to boost the pay of Disney World’s emergency workers.

Starting pay for a firefighter/paramedic will increase from $55,000 to $66,000 as part of the three-year agreement.

At their November meeting, board members approved a separate union contract covering battalion chiefs and captains that includes a 13% wage adjustment in 2024 and a 5% adjustment in 2025 and 2026."

 

UNCgolf

Well-Known Member
I just looked at the actual requests and some of them are a little silly -- mainly because they're likely going to get a ton of junk they don't actually care about. I wouldn't be surprised if they then turn around and complain that Disney gave them a bunch of junk and are acting in bad faith when it's actually what they requested.

They're asking for all communications, internal and external, that mention Ron DeSantis, the two Senate bills, or the House bill, and as well as all communications with the different media outlets. They could end up with thousands of listserv newsletter type emails from various companies that mention DeSantis or one of the bills -- that's all dependent on who the Disney custodians are (and how many there are) but anything like that would technically be responsive to the document requests. The request relating to the media communications could (and likely would) bring in loads of emails that relate to standard Disney operations/marketing and have nothing to do with the issues at hand.

Being overly broad isn't only burdensome to the party making the productions -- it also makes things more difficult for the party receiving the productions. They have to dig through all of the junk that's not remotely relevant to the case to identify documents that are actually useful.

Requests 13 and 14 are likely to be blanket privileged and they probably won't actually see a single document from those requests. They'll just end up on a privilege log.

Finally, I noticed they're asking to categorize every produced document by request number. That's something we generally only do for certain government investigations; it slows down the process significantly to have document reviewers potentially place numerous categorization tags on each document, since some could be responsive to multiple requests. Disney may just mass categorize them on the back end based on which search terms were used to bring in the documents (or another similar process), which won't be that accurate but is much faster/simpler.
 
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sblank

Member
Being overly broad isn't only burdensome to the party making the productions -- it also makes things more difficult for the party receiving the productions. They have to dig through all of the junk that's not remotely relevant to the case to identify documents that are actually useful.

This makes sense considering the district's leadership has every incentive to drag this out as long as possible and there's no costs for them to do so.
 

Batman'sParents

Active Member
Update from the Orlando Sentinel on the cash stipend as a replacement for park passes/discounts for district firefighters.

"Unionized firefighters are waiting to receive cash stipends to make up for Disney perks ended by Gov. Ron DeSantis’ tourism oversight district.

About 200 unionized employees – more than half of the district’s workforce – haven’t gotten the $3,000 stipend because of a disagreement with the district over the benefit’s value, said Jon Shirey, president of the district’s firefighters union.

“We have had one bargaining session over the stipend, but it went nowhere,” he said.

The deadlock comes as administrator Glen Gilzean touts increased employee morale at the Central Florida Tourism Oversight District made possible through his “open door” policy and additional benefits. More than 40 of the district’s roughly 370 employees have resigned or retired since the state seized control in February.

The district’s board approved the stipend at their meeting in September.

“Under the current contract, the district cannot provide additional benefits without renegotiating the contract,” said Alexei Woltornist, a district spokesman. “Contract negotiations are currently underway, and we cannot comment further at this time.”

Union officials estimated the value of the Disney passes and discounts to be at least $5,000. The Disney perks program covered theme park entry for employees, their spouses and three guests, an employee familiar with the benefit said. The program also included discounts at Disney restaurants and hotels.

DeSantis’ hand-picked tourism oversight board took aim at the perk, calling it an “unethical” arrangement that exclusively benefited Disney over other businesses. But the board faced a backlash from some employees who said the theme park passes were a key factor in their decision to work there.

At this month’s meeting, Gilzean said employees would get two additional paid holidays — Veterans Day and the day before Thanksgiving — when outlining his efforts to boost employee morale. Those days are also subject to bargaining, so union members aren’t presently eligible for those paid holidays, Shirey said.

The Reedy Creek Professional Firefighters, the union led by Shirey, endorsed DeSantis’ re-election bid with the district’s future still in question. Formerly known as Reedy Creek, the Central Florida Tourism Oversight District provides fire protection and other government services to Disney World.

Union officials praised DeSantis when he appointed the new board earlier this year. Shirey accused the previous Disney-friendly board and management of neglecting public safety by not addressing staffing and equipment shortages.

The new administration approved a union contract in July, ending about five years of negotiations and answering the governor’s calls to boost the pay of Disney World’s emergency workers.

Starting pay for a firefighter/paramedic will increase from $55,000 to $66,000 as part of the three-year agreement.

At their November meeting, board members approved a separate union contract covering battalion chiefs and captains that includes a 13% wage adjustment in 2024 and a 5% adjustment in 2025 and 2026."

Without the added discounts or passes, is working as a firefighter or EMT for CFTOD still attractive?

I would want to know how wages compare to the city of Orlando and Orange County. If you don't have the passes anymore, you may as well go where you can make more.

I know that for some odd reason firefighters who work for the City of Tampa have really good wages and retirements.
 

lazyboy97o

Well-Known Member

Rhinocerous

Premium Member
I haven't read their request, but as someone who deals with ediscovery in large corporate litigation, we typically provide documents in TIFF format along with a TXT file of the extracted text (which is obviously searchable) and a load file with metadata. We also usually provide Excels natively, along with some other less common files like videos or audio. That's more or less standard practice in corporate litigation.

Sometimes productions are done entirely as PDFs (again other than native Excels) but that's not regular practice.

I also do a lot of government investigation work, and it's very similar. Some government departments/commissions require native production of PowerPoints along with Excels, and they often have some other specific requirements, but it's still generally TIFF/extracted text TXT file/metadata.

EDIT: I just skimmed through the document request and it's not really out of the ordinary. They are requesting native PowerPoints, but while that's less common, it's certainly not unheard of. The privilege log request is pretty standard too.
Okay thanks. As I said, I don’t know how these things usually go.
 

Stripes

Premium Member
That and they might have finally realized that ramming through a summary judgement isn't a sure thing.

Since the start of this they've just "declared" "facts" and acted like they're so obvious on the face of it they didn't even need to prove their allegations.
Some of the facts are obvious on their face but it’s not clear how the district has standing to bring such claims. For instance, clearly the district and Disney signed a contract giving Disney development rights within the cities of BL and LBV. Those development rights, at the time, were not under the district’s control. They were under the control of cities (however the development rights are now under the control of the district).

The cities were harmed by the contract, not the district. It is unclear how the district has standing to challenge the contracts because the cities were harmed.
 

Isamar

Well-Known Member
I suspect that the current board is mostly interested in a lengthy expensive process. They’re running the place in the meantime and everyone makes money while they wreak as much havoc as possible. No matter what happens in the end, they walk away unscathed and Disney foots the bill for the whole ugly process.
 

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