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Filing # 145711448 E-Filed 03/15/2022 10:30:04 AM
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA.
CASE NO.: 50-2021-CA-010108
MARION J. YOUNG BUTERA AND
THOMAS BUTERA, her spouse
Plaintiff,
vs.
EDENS LIMITED PARTNERSHIP D/B/A
SUNSHINE SQUARE PLAZA and
THE BRIGHTVIEW LANDSCAPES, LLC
Defendant(s).
EDENS LIMITED PARTNERSHIP D/B/A
SUNSHINE SQUARE PLAZA,
Cross-Plaintiff,
vs.
THE BRIGHTVIEW LANDSCAPES, LLC,
Cross-Defendant
DEFENDANT/CROSS-PLAINTIFF EDENS LIMITED PARTNERSHIP D/B/A SUNSHINE
SQUARE PLAZA’S NOTICE OF SERVICE OF INSURANCE INTERROGATORIES
TO DEFENDANT/CROSS-DEFENDANT, THE BRIGHTVIEW LANDSCAPES, LLC
YOU ARE HEREBY NOTIFIED that pursuant to Florida Rules of Civil Procedure 1.340 and
other applicable rules, the undersigned files this, its Notice of propounding Insurance Interrogatories to
Defendant/Cross Defendant, THE BRIGHTVIEW LANSCAPES, LLC.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 15th day of March, 2022, I electronically filed the foregoing
document with the Clerk of Court using Florida Courts eFiling Portal. I also certify that the foregoing
document is being served this day on all counsel of record or pro se parties identified as follows, either via
Pg. 1
'** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/15/2022 10:30:04 AM ***transmission of Notices of Electronic Filing generated by Florida Courts eFiling Portal or in some other
authorized manner for those counsel or parties who are not authorized to receive electronic Notices of
Filing: Barry C. Hoffman, Esquire; Counsel for Plaintiff at Law Offices of Barry G. Hoffman Law Firm,
9045 La Fontana Boulevard, Suite 1106, Boca Raton, FL 33434; hchlawoffice@aol.com; David J. Majcak,
Esquire; Counsel for Defendant, The Brightview Landscapes, LLC, at Law Offices of Goldberg Segalla,
LLP, 500 S. Australian Avenue, Suite 1000, West Palm Beach, FL 33401; dmajcak@goldbergsegalla.com;
kgomberg@goldbergsegalla.com
LAW OFFICES OF JAMES W. KEHOE, III
Counsel for DEFENDANT(S)
3230 West Commercial Boulevard, Ste. 250
Fort Lauderdale, Florida 33309
Mailing Address:
P.O. Box 2903
Hartford, CT 06104-2903
Telephone No.: (954) 677-3708
Facsimile No.: (866) 292-4641
E-mail: MKatler@travelers.com;
EGuilbea@travelers.com;
TGruende@travelers.com
welch? Rat lon
MITCHELL H. KATLER, ESQUIRE
Florida Bar Number: 454982
Pg. 2INSURANCE INTERROGATORIES TO DEFENDANT/CROSS -DEFENDANT, THE
BRIGHTVIEW LANDSCAPES, LLC
(If answering for any other person or entity, answer with respect for that person or entity, unless otherwise
state)
1. Please state whether the Defendant carried insurance for the accident as alleged in the
Complaint, at the time and place alleged in the Complaint.
2. Please state the name of the insurance carrier.
ae Please state the policy limits of such insurance.
4. Please state whether there is an excess liability insurance carrier which covers the incident as
alleged in the Complaint
A. If yes, please state the limits of such excess coverage and the name of the carrier.
5. Has any liability insurance carrier informed you that a question of coverage exists concerning the
subject accident.
A. If yes, please state whether or not a defense is being offered to you under a reservation of
rights.
6. Please state the local address, if any, of the insurance carriers referred to in your answers to
interrogatories (3) and (4) above.
Pg. 37.
Please state the home office addresses of such insurance carriers.
Pg. 4Signature
STATE OF FLORIDA )
)ss:
COUNTY OF )
BEFORE ME, the undersigned authority, personally appeared,
who, after being first duly sworn, acknowledged that
he/she is the person duly authorized to execute the foregoing Answers to Interrogatories, and that he/she
has read the answers and that they are true and correct to the best of his/her knowledge and belief, and
he/she executed same in my presence, this day of , 2022.
Notary Public
My Commission Expires:
Pg. 5
Preview
Filing # 145711448 E-Filed 03/15/2022 10:30:04 AM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO.: 50-2021-CA-010108 MARION J. YOUNG BUTERA AND THOMAS BUTERA, her spouse Plaintiff, vs. EDENS LIMITED PARTNERSHIP D/B/A SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendant(s). EDENS LIMITED PARTNERSHIP D/B/A SUNSHINE SQUARE PLAZA, Cross-Plaintiff, vs. THE BRIGHTVIEW LANDSCAPES, LLC, Cross-Defendant DEFENDANT/CROSS-PLAINTIFF EDENS LIMITED PARTNERSHIP D/B/A SUNSHINE SQUARE PLAZA’S NOTICE OF SERVICE OF INSURANCE INTERROGATORIES TO DEFENDANT/CROSS-DEFENDANT, THE BRIGHTVIEW LANDSCAPES, LLC YOU ARE HEREBY NOTIFIED that pursuant to Florida Rules of Civil Procedure 1.340 and other applicable rules, the undersigned files this, its Notice of propounding Insurance Interrogatories to Defendant/Cross Defendant, THE BRIGHTVIEW LANSCAPES, LLC. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 15th day of March, 2022, I electronically filed the foregoing document with the Clerk of Court using Florida Courts eFiling Portal. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified as follows, either via Pg. 1 '** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 03/15/2022 10:30:04 AM ***transmission of Notices of Electronic Filing generated by Florida Courts eFiling Portal or in some other authorized manner for those counsel or parties who are not authorized to receive electronic Notices of Filing: Barry C. Hoffman, Esquire; Counsel for Plaintiff at Law Offices of Barry G. Hoffman Law Firm, 9045 La Fontana Boulevard, Suite 1106, Boca Raton, FL 33434; hchlawoffice@aol.com; David J. Majcak, Esquire; Counsel for Defendant, The Brightview Landscapes, LLC, at Law Offices of Goldberg Segalla, LLP, 500 S. Australian Avenue, Suite 1000, West Palm Beach, FL 33401; dmajcak@goldbergsegalla.com; kgomberg@goldbergsegalla.com LAW OFFICES OF JAMES W. KEHOE, III Counsel for DEFENDANT(S) 3230 West Commercial Boulevard, Ste. 250 Fort Lauderdale, Florida 33309 Mailing Address: P.O. Box 2903 Hartford, CT 06104-2903 Telephone No.: (954) 677-3708 Facsimile No.: (866) 292-4641 E-mail: MKatler@travelers.com; EGuilbea@travelers.com; TGruende@travelers.com welch? Rat lon MITCHELL H. KATLER, ESQUIRE Florida Bar Number: 454982 Pg. 2INSURANCE INTERROGATORIES TO DEFENDANT/CROSS -DEFENDANT, THE BRIGHTVIEW LANDSCAPES, LLC (If answering for any other person or entity, answer with respect for that person or entity, unless otherwise state) 1. Please state whether the Defendant carried insurance for the accident as alleged in the Complaint, at the time and place alleged in the Complaint. 2. Please state the name of the insurance carrier. ae Please state the policy limits of such insurance. 4. Please state whether there is an excess liability insurance carrier which covers the incident as alleged in the Complaint A. If yes, please state the limits of such excess coverage and the name of the carrier. 5. Has any liability insurance carrier informed you that a question of coverage exists concerning the subject accident. A. If yes, please state whether or not a defense is being offered to you under a reservation of rights. 6. Please state the local address, if any, of the insurance carriers referred to in your answers to interrogatories (3) and (4) above. Pg. 37. Please state the home office addresses of such insurance carriers. Pg. 4Signature STATE OF FLORIDA ) )ss: COUNTY OF ) BEFORE ME, the undersigned authority, personally appeared, who, after being first duly sworn, acknowledged that he/she is the person duly authorized to execute the foregoing Answers to Interrogatories, and that he/she has read the answers and that they are true and correct to the best of his/her knowledge and belief, and he/she executed same in my presence, this day of , 2022. Notary Public My Commission Expires: Pg. 5