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Filing # 141498770 E-Filed 01/06/2022 02:52:12 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-Defendants.
/
DEFENDANT/CROSS-DEFENDANT, THE BRIGHTVIEW LANDSCAPES, LLC'S,
AMENDED RESPONSES TO PLAINTIFF’S REQUEST TO PRODUCE
(SERVED OCTOBER 20, 2021)
COMES NOW the Defendant/Cross-Defendant, THE BRIGHTVIEW LANDSCAPES,
LLC, by and through its undersigned counsel, and pursuant to Fla. R. Civ. P. 1.350, and hereby
files its Amended Responses to Defendant/Cross-Plaintiff, EDENS LIMITED PARTNERSHIP
d/b/a SUNSHINE SQUARE PLAZA’s Request to Produce (served October 20, 2021), and states
as follows:
31564582.v1
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 01/06/2022 02:52:12 PM ***Ll. Copy of all policies of insurance and associated declarations pages that provide,
provided, and/or may provide benefits and/or coverage for any or all of the economic and non-
economic damages sought in this case by the Plaintiffs.
RESPONSE: Defendant produces Insurance Policy No.: XSL G28103670 001, with
confidential premium information redacted.
2. Copies of any and all policies of insurance that may be applicable to the incident as
described in the Complaint including but not limited to Commercial Liability Insurance Policy No.
G28103670 to Brightview Landscapes, LLC for the period effective October 1, 2017 through
October 1, 2018 including any and all additional Insured endorsement.
RESPONSE: Defendant produces Insurance Policy No.: XSL G28103670 001, with
confidential premium information redacted.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded
electronically to Barry G. Hoffman, Esquire, (Atforney for Plaintiff) hchlawoffice@aol.com,
BARRY G. HOFFMAN LAW FIRM, P.A., 9045 La Fontana Blvd., Suite 106, Boca Raton, FL
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, III, 3230 West Commercial Blvd.,
Suite 250, Ft. Lauderdale, FL 33309, this 6th day of January 2022. The certificate is taken as
prima facie proof of such service in compliance with Fla. R. Jud. Admin. 2.516.
/s/ David Majcak
GOLDBERG SEGALLA, LLP
David J. Majcak, Esquire
Florida Bar No. 0073883
222 Lakeview Avenue, Suite 800
West Palm Beach, FL 33401
(561) 618-4469 Office
(561) 618-4549 Fax
email designations:
dmajcak@goldbergsegalla.com
dharrison@goldbergsegalla.com
31564582.v1
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Filing # 141498770 E-Filed 01/06/2022 02:52:12 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-Defendants. / DEFENDANT/CROSS-DEFENDANT, THE BRIGHTVIEW LANDSCAPES, LLC'S, AMENDED RESPONSES TO PLAINTIFF’S REQUEST TO PRODUCE (SERVED OCTOBER 20, 2021) COMES NOW the Defendant/Cross-Defendant, THE BRIGHTVIEW LANDSCAPES, LLC, by and through its undersigned counsel, and pursuant to Fla. R. Civ. P. 1.350, and hereby files its Amended Responses to Defendant/Cross-Plaintiff, EDENS LIMITED PARTNERSHIP d/b/a SUNSHINE SQUARE PLAZA’s Request to Produce (served October 20, 2021), and states as follows: 31564582.v1 *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 01/06/2022 02:52:12 PM ***Ll. Copy of all policies of insurance and associated declarations pages that provide, provided, and/or may provide benefits and/or coverage for any or all of the economic and non- economic damages sought in this case by the Plaintiffs. RESPONSE: Defendant produces Insurance Policy No.: XSL G28103670 001, with confidential premium information redacted. 2. Copies of any and all policies of insurance that may be applicable to the incident as described in the Complaint including but not limited to Commercial Liability Insurance Policy No. G28103670 to Brightview Landscapes, LLC for the period effective October 1, 2017 through October 1, 2018 including any and all additional Insured endorsement. RESPONSE: Defendant produces Insurance Policy No.: XSL G28103670 001, with confidential premium information redacted. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded electronically to Barry G. Hoffman, Esquire, (Atforney for Plaintiff) hchlawoffice@aol.com, BARRY G. HOFFMAN LAW FIRM, P.A., 9045 La Fontana Blvd., Suite 106, Boca Raton, FL 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, III, 3230 West Commercial Blvd., Suite 250, Ft. Lauderdale, FL 33309, this 6th day of January 2022. The certificate is taken as prima facie proof of such service in compliance with Fla. R. Jud. Admin. 2.516. /s/ David Majcak GOLDBERG SEGALLA, LLP David J. Majcak, Esquire Florida Bar No. 0073883 222 Lakeview Avenue, Suite 800 West Palm Beach, FL 33401 (561) 618-4469 Office (561) 618-4549 Fax email designations: dmajcak@goldbergsegalla.com dharrison@goldbergsegalla.com 31564582.v1