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Filing # 137864318 E-Filed 11/03/2021 07:48:39 PM
IN THE CIRCUIT COURT OF THE 1Sth
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
MARION J. YOUNG BUTERA
AND THOMAS BUTERA, her spouse,
Plaintiffs, CASE NO: 50-2021-CA-010108
v.
EDENS LIMITED PARTNERSHIP d/b/a
SUNSHINE SQUARE PLAZA and THE
BRIGHTVIEW LANDSCAPES, LLC,
Defendants.
EDENS LIMITED PARTNERSHIP d/b/a
SUNSHINE SQUARE PLAZA,
Cross-Plaintiff,
Vv.
THE BRIGHTVIEW LANDSCAPES, LLC,
Cross-Defendant.
/
DEFENDANT, THE BRIGHTVIEW LANDSCAPES, LLC’S NOTICE OF SERVING
MEDICAL SPECIAL INTERROGATORIES
TO PLAINTIFF, MARION J. YOUNG BUTERA
COMES NOW the Defendant, THE BRIGHTVIEW LANDSCAPES, LLC, by and
through its undersigned counsel, and hereby gives notice that pursuant to Rule 1.340, Florida Rules
of Civil Procedure, its Medical Special Interrogatories numbered 1 with subparts (a)(1) — (a) (5)
have been directed to the Plaintiff, MARION J. YOUNG BUTERA.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded
electronically to Barry G. Hoffman, Esquire, (Attorney for Plaintiff) hchlawoffice@aol.com,
BARRY G. HOFFMAN LAW FIRM, P.A., 9045 La Fontana Blvd., Suite 106, Boca Raton, FL
25604620.v1
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/03/2021 07:48:39 PM ***33434; Mitchell H. Katler, Esquire, (Attorney for Defendant, Edens Limited Partnership d/b/a
Sunshine Square Plaza), MKatler@travelers.com, EGuilbea@travelers.com;
TGruende@travelers.com; Law Offices of James W. Kehoe, II, 3230 West Commercial Blvd.,
Suite 250, Ft. Lauderdale, FL 33309, this 3RD day of November 2021. The certificate is taken
as prima facie proof of such service in compliance with Fla. R. Jud. Admin. 2.516.
/s/ David J. Majcak
GOLDBERG SEGALLA, LLP
David J. Majcak, Esquire
Florida Bar No. 0073883
Rodney Janis, Esquire
Florida Bar No. 647896
222 Lakeview Avenue, Suite 800
West Palm Beach, FL 33401
(561) 618-4466 Office
(561) 618-4549 Fax
email designations:
dmajcak@goldbergsegalla.com
kgomberg@goldbergsegalla.com
25604620.v1MEDICAL SPECIAL INTERROGATORIES TO PLAINTIFF
1. With respect to each medical provider who offered care and treatment to the Plaintiff which
was allegedly caused by the accident that is the subject of this lawsuit, please state the
following information for each provider:
a. For each provider state the following:
1. Name of provider;
2. The provider’s total bill;
3. Amounts of reductions in any bills paid to the provider by payments of third
parties such as Medicare/Medicaid, HMO/Health Insurance coverage or the
like;
4. The total amount of provider’s bill that reflects any unpaid medical charges
along with the net amount paid to the provider after reductions were taken in
their bill;
5. Whether the entity taking the reduction has asserted a lien (and if so, the
amount), or if a provider has any contractual right to receive repayment for
the amount of money they have paid to medical providers.
25604620.v1VERIFICATION
MARION J. YOUNG BUTERA
STATE OF FLORIDA )
) ss:
COUNTY OF )
I HEREBY CERTIFY, that on this day before me, an officer authorized to take
acknowledgements according to the laws of the State of Florida, duly qualified and acting,
personally appeared MARION J. YOUNG BUTERA, [ ]who is personally known to me; or [ }who
has produced for identification, ; and who has read the
attached Answers to Medical Special Interrogatories, and that the same are true and correct to the
best of her knowledge and has executed the foregoing.
WITNESS my hand and official seal in the County and State last aforesaid this day
of 52021.
PRINT NAME:
NOTARY PUBLIC, STATE OF
Commission Number:
My Commission Expires:
SEAL
25604620.v1
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Filing # 137864318 E-Filed 11/03/2021 07:48:39 PM IN THE CIRCUIT COURT OF THE 1Sth JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA MARION J. YOUNG BUTERA AND THOMAS BUTERA, her spouse, Plaintiffs, CASE NO: 50-2021-CA-010108 v. EDENS LIMITED PARTNERSHIP d/b/a SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC, Defendants. EDENS LIMITED PARTNERSHIP d/b/a SUNSHINE SQUARE PLAZA, Cross-Plaintiff, Vv. THE BRIGHTVIEW LANDSCAPES, LLC, Cross-Defendant. / DEFENDANT, THE BRIGHTVIEW LANDSCAPES, LLC’S NOTICE OF SERVING MEDICAL SPECIAL INTERROGATORIES TO PLAINTIFF, MARION J. YOUNG BUTERA COMES NOW the Defendant, THE BRIGHTVIEW LANDSCAPES, LLC, by and through its undersigned counsel, and hereby gives notice that pursuant to Rule 1.340, Florida Rules of Civil Procedure, its Medical Special Interrogatories numbered 1 with subparts (a)(1) — (a) (5) have been directed to the Plaintiff, MARION J. YOUNG BUTERA. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded electronically to Barry G. Hoffman, Esquire, (Attorney for Plaintiff) hchlawoffice@aol.com, BARRY G. HOFFMAN LAW FIRM, P.A., 9045 La Fontana Blvd., Suite 106, Boca Raton, FL 25604620.v1 *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/03/2021 07:48:39 PM ***33434; Mitchell H. Katler, Esquire, (Attorney for Defendant, Edens Limited Partnership d/b/a Sunshine Square Plaza), MKatler@travelers.com, EGuilbea@travelers.com; TGruende@travelers.com; Law Offices of James W. Kehoe, II, 3230 West Commercial Blvd., Suite 250, Ft. Lauderdale, FL 33309, this 3RD day of November 2021. The certificate is taken as prima facie proof of such service in compliance with Fla. R. Jud. Admin. 2.516. /s/ David J. Majcak GOLDBERG SEGALLA, LLP David J. Majcak, Esquire Florida Bar No. 0073883 Rodney Janis, Esquire Florida Bar No. 647896 222 Lakeview Avenue, Suite 800 West Palm Beach, FL 33401 (561) 618-4466 Office (561) 618-4549 Fax email designations: dmajcak@goldbergsegalla.com kgomberg@goldbergsegalla.com 25604620.v1MEDICAL SPECIAL INTERROGATORIES TO PLAINTIFF 1. With respect to each medical provider who offered care and treatment to the Plaintiff which was allegedly caused by the accident that is the subject of this lawsuit, please state the following information for each provider: a. For each provider state the following: 1. Name of provider; 2. The provider’s total bill; 3. Amounts of reductions in any bills paid to the provider by payments of third parties such as Medicare/Medicaid, HMO/Health Insurance coverage or the like; 4. The total amount of provider’s bill that reflects any unpaid medical charges along with the net amount paid to the provider after reductions were taken in their bill; 5. Whether the entity taking the reduction has asserted a lien (and if so, the amount), or if a provider has any contractual right to receive repayment for the amount of money they have paid to medical providers. 25604620.v1VERIFICATION MARION J. YOUNG BUTERA STATE OF FLORIDA ) ) ss: COUNTY OF ) I HEREBY CERTIFY, that on this day before me, an officer authorized to take acknowledgements according to the laws of the State of Florida, duly qualified and acting, personally appeared MARION J. YOUNG BUTERA, [ ]who is personally known to me; or [ }who has produced for identification, ; and who has read the attached Answers to Medical Special Interrogatories, and that the same are true and correct to the best of her knowledge and has executed the foregoing. WITNESS my hand and official seal in the County and State last aforesaid this day of 52021. PRINT NAME: NOTARY PUBLIC, STATE OF Commission Number: My Commission Expires: SEAL 25604620.v1