On August 31, 2021 a
Party Notice
was filed
involving a dispute between
Furer, Joy,
and
Designedvr Holdings Llc,
Gg Re Hollywood Beach 613 Llc,
Relaxpro Llc,
for 3
in the District Court of Broward County.
Preview
Filing# 147768282 E-Filed 04/15/2022 11:10:45 AM
INTHE CIRCUIT COURT OF THE 17
,TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JOY FURER, GENERAL JURISDICTION DIVISION
Plaintiff, CASE NO: CACE-21-016578
VS.
GG RE HOLLYWOOD BEACH 613 LLC,
and DESIGNEDVR HOLDINGS LLC,
Defendants.
i
PLAINTIFF'S NOTICE OF FILING AFFIDAVIT IN
SUPPORT OF MOTION FOR PROTECTIVE ORDER
COMES NOW, JOY
Plaintiff, FURER, by and through the undersigned counsel, and
gives notice to the Court and Counsel for Defendants that Plaintiffhas filed the followingmaterials
in support of her Motion for Protective Order to Permit Plaintiff to Appear Remotely for her
Deposition:
1. Affidavit of Joy Furer
[CERTIFICATE OF SERVICE ON FOLLOWING PAGE]
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/15/2022 11:10:44 AM.****
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy o f the foregoingwas served by
Electronic Service via the Florida Courts E-filingEportalpursuant to the Supreme Court
Administrative Order AOSC13-49 on April 15,2022.
FLANAGAN & BODENHEIMER INJURY AND
WRONGFUL DEATH LAW FIRM
Attorney for Plaintiff
2525 Ponce de Leon Blvd., Suite 650
Coral Gables, FL 331345
Tel:(305) 637-4143
Fax: (305) 397-2636
/s/ Zachary Bodenheimer
BY
Zachary D. Bodenheimer, Esq.,Fla. Bar No.. 91322
Emails: zdb@florida-justice.corn
com
mtfassistant@florida-justice.
TH
INTHE CIRCUIT COURT OF THE 17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JOY FURER, GENERAL JURISDICTION DIVISION
Plaintiff, CASE NO: CACE-21-016578
VS.
GG RE HOLLYWOOD BEACH 613 LLC,
and DESIGNEDVR HOLDINGS LLC,
Defendants.
i
COUNTY OF KINGS
: SS
STATE OF NEW YORK )
AFFIDAVIT OF JOY FURER
BEFORE ME NOW, the undersigned,personally appeared JOY FURER, who after being duly
sworn, deposes and states as follows:
1. My name is JOY FURER. I am over twenty-one years of age and a resident ofNew York
and am competent to testify.
2. I am the Plaintiff in the above-captioned lawsuit.
3. I am requestingpermission to appear at my depositionvia Zoom given my concerns over
COVID-19 and my current physicalcondition.
4. I have asthma and I am immunocompromised, and I am fearful of contractingCOVID-19
if I am forced to travel to Florida via air travel.
5. I have contracted COVID-19 in the past and developed acute bronchitis.
6. I am also sufferingfrom injuriesrelated to this incident that make it difficult for me to
ambulate.
7. I currentlyuse an assisted walking device.
8. My treatingorthopedicdoctor on March 2, 2022, opined that I am 100% disabled at this
time.
9. It would be a tremendous hardshipfor me to be forced to travel to Florida to sit for a
in this
deposition case.
FURTHER AFFIANT SAYETH NAUGHT.
GMRAZJ
J?? FURER
SWDRN TO AND SUBSCRIBED TO before me, at Kings-fl&u**,
New York this
13 dayof ,L 1 ,2022.
Known
Personally
Driver' SU-ense
0453L901633934
NO?j?ARYPUBLIC
DIANAMURIEL
Notary Public -
State of New York
NO. 01MU6331764
Qualified in Bronx County
My Commission Expires Oct 19, 2023
Document Filed Date
April 15, 2022
Case Filing Date
August 31, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing# 147768282 E-Filed 04/15/2022 11:10:45 AM INTHE CIRCUIT COURT OF THE 17 ,TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JOY FURER, GENERAL JURISDICTION DIVISION Plaintiff, CASE NO: CACE-21-016578 VS. GG RE HOLLYWOOD BEACH 613 LLC, and DESIGNEDVR HOLDINGS LLC, Defendants. i PLAINTIFF'S NOTICE OF FILING AFFIDAVIT IN SUPPORT OF MOTION FOR PROTECTIVE ORDER COMES NOW, JOY Plaintiff, FURER, by and through the undersigned counsel, and gives notice to the Court and Counsel for Defendants that Plaintiffhas filed the followingmaterials in support of her Motion for Protective Order to Permit Plaintiff to Appear Remotely for her Deposition: 1. Affidavit of Joy Furer [CERTIFICATE OF SERVICE ON FOLLOWING PAGE] *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/15/2022 11:10:44 AM.**** CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy o f the foregoingwas served by Electronic Service via the Florida Courts E-filingEportalpursuant to the Supreme Court Administrative Order AOSC13-49 on April 15,2022. FLANAGAN & BODENHEIMER INJURY AND WRONGFUL DEATH LAW FIRM Attorney for Plaintiff 2525 Ponce de Leon Blvd., Suite 650 Coral Gables, FL 331345 Tel:(305) 637-4143 Fax: (305) 397-2636 /s/ Zachary Bodenheimer BY Zachary D. Bodenheimer, Esq.,Fla. Bar No.. 91322 Emails: zdb@florida-justice.corn com mtfassistant@florida-justice. TH INTHE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JOY FURER, GENERAL JURISDICTION DIVISION Plaintiff, CASE NO: CACE-21-016578 VS. GG RE HOLLYWOOD BEACH 613 LLC, and DESIGNEDVR HOLDINGS LLC, Defendants. i COUNTY OF KINGS : SS STATE OF NEW YORK ) AFFIDAVIT OF JOY FURER BEFORE ME NOW, the undersigned,personally appeared JOY FURER, who after being duly sworn, deposes and states as follows: 1. My name is JOY FURER. I am over twenty-one years of age and a resident ofNew York and am competent to testify. 2. I am the Plaintiff in the above-captioned lawsuit. 3. I am requestingpermission to appear at my depositionvia Zoom given my concerns over COVID-19 and my current physicalcondition. 4. I have asthma and I am immunocompromised, and I am fearful of contractingCOVID-19 if I am forced to travel to Florida via air travel. 5. I have contracted COVID-19 in the past and developed acute bronchitis. 6. I am also sufferingfrom injuriesrelated to this incident that make it difficult for me to ambulate. 7. I currentlyuse an assisted walking device. 8. My treatingorthopedicdoctor on March 2, 2022, opined that I am 100% disabled at this time. 9. It would be a tremendous hardshipfor me to be forced to travel to Florida to sit for a in this deposition case. FURTHER AFFIANT SAYETH NAUGHT. GMRAZJ J?? FURER SWDRN TO AND SUBSCRIBED TO before me, at Kings-fl&u**, New York this 13 dayof ,L 1 ,2022. Known Personally Driver' SU-ense 0453L901633934 NO?j?ARYPUBLIC DIANAMURIEL Notary Public - State of New York NO. 01MU6331764 Qualified in Bronx County My Commission Expires Oct 19, 2023