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Filing # 135442785 E-Filed 09/28/2021 10:48:26 AM
,TH
IN THE 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,
Defendant.
i
PLAINTIFF'S NOTICE OF SERVICE OF REQUESTS
FOR ADMISSION TO DEFENDANT GG RE HOLLYWOOD BEACH 613, LLC
COMES NOW, Plaintiff, JOY FURER, by and through his undersigned attorney, and
propounds the attached Requests for Admission to Defendant, GG RE HOLLYWOOD BEACH
613 LLC, to be answered in writing, admitted or denied, within forty-five (45) days, pursuant to
the applicable Florida Rules of Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFYthat an
original and one copy of Plaintiff's Requests for Admissions
were served with the complaint in this matter upon Defendant, GG RE HOLLYWOODBEACH 613
LLC
BODENHEIMER PERSONAL INJURY
LAW FIRM P.A.
Attorney for Plaintiff
4601 Sheridan Street, Suite 320
Hollywood, FL 33021
Tel: (954) 712-7402
Fax: (954) 376-7575
/s/ Zachary Bodenheimer
BY
Zachary D. Bodenheimer, Esq., Fla. Bar No.. 91322
Emails: irm.com
[rm. com
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/28/2021 10:48:25 AM.****
PLAINTIFF'S FIRST REQUESTS FOR
ADMISSION TO DEFENDANT GG RE HOLLYWOOD BEACH 613 LLC
1. On January 5, 2021, GG RE HOLLYWOOD BEACH 613 LLC owned the property at
2012 N Surf Rd, Hollywood, FL.
2. On January 5, 2021, GG RE HOLLYWOOD BEACH 613 LLC controlled the property at
2012 N Surf Rd, Hollywood, FL, including the common areas.
3. Prior to January 5, 2021, Defendant GG RE HOLLYWOOD BEACH 613 LLC and its
owners, managers, directors, employees, or agents were aware that individualshad been
victims of crime in or around the address at 2012 N Surf Rd, Hollywood, FL.
4. Prior to January 5, 2021, Defendant GG RE HOLLYWOOD BEACH 613 LLC and its
owners, managers, directors, employees, or agents did not conduct any type of security
analysis for the property at 2012 N Surf Rd, Hollywood, FL.
5. Prior to January 5, 2021, Defendant GG RE HOLLYWOOD BEACH 613 LLC and its
owners, managers, directors, employees, or agents did not hire any other individual or
entity to conduct any type of security analysis for the property at 2012 N Surf Rd,
Hollywood, FL.
6. Prior to January 5, 2021, Defendant GG RE HOLLYWOOD BEACH 613 LLC and its
owners, managers, directors, employees, or agents did not hire any security guards or
security company to provide security at the property at 2012 N SurfRd, Hollywood, FL.
7. On January 5,2021, the exterior surveillance cameras for the property at 2012 N Surf Rd,
Hollywood, FL were not operable.
8. On January 5, 2021, Joy Furer was a lawful invitee at the property at 2012 N Surf Rd,
Hollywood, FL.
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Filing # 135442785 E-Filed 09/28/2021 10:48:26 AM ,TH IN THE 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, Defendant. i PLAINTIFF'S NOTICE OF SERVICE OF REQUESTS FOR ADMISSION TO DEFENDANT GG RE HOLLYWOOD BEACH 613, LLC COMES NOW, Plaintiff, JOY FURER, by and through his undersigned attorney, and propounds the attached Requests for Admission to Defendant, GG RE HOLLYWOOD BEACH 613 LLC, to be answered in writing, admitted or denied, within forty-five (45) days, pursuant to the applicable Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFYthat an original and one copy of Plaintiff's Requests for Admissions were served with the complaint in this matter upon Defendant, GG RE HOLLYWOODBEACH 613 LLC BODENHEIMER PERSONAL INJURY LAW FIRM P.A. Attorney for Plaintiff 4601 Sheridan Street, Suite 320 Hollywood, FL 33021 Tel: (954) 712-7402 Fax: (954) 376-7575 /s/ Zachary Bodenheimer BY Zachary D. Bodenheimer, Esq., Fla. Bar No.. 91322 Emails: irm.com [rm. com *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/28/2021 10:48:25 AM.**** PLAINTIFF'S FIRST REQUESTS FOR ADMISSION TO DEFENDANT GG RE HOLLYWOOD BEACH 613 LLC 1. On January 5, 2021, GG RE HOLLYWOOD BEACH 613 LLC owned the property at 2012 N Surf Rd, Hollywood, FL. 2. On January 5, 2021, GG RE HOLLYWOOD BEACH 613 LLC controlled the property at 2012 N Surf Rd, Hollywood, FL, including the common areas. 3. Prior to January 5, 2021, Defendant GG RE HOLLYWOOD BEACH 613 LLC and its owners, managers, directors, employees, or agents were aware that individualshad been victims of crime in or around the address at 2012 N Surf Rd, Hollywood, FL. 4. Prior to January 5, 2021, Defendant GG RE HOLLYWOOD BEACH 613 LLC and its owners, managers, directors, employees, or agents did not conduct any type of security analysis for the property at 2012 N Surf Rd, Hollywood, FL. 5. Prior to January 5, 2021, Defendant GG RE HOLLYWOOD BEACH 613 LLC and its owners, managers, directors, employees, or agents did not hire any other individual or entity to conduct any type of security analysis for the property at 2012 N Surf Rd, Hollywood, FL. 6. Prior to January 5, 2021, Defendant GG RE HOLLYWOOD BEACH 613 LLC and its owners, managers, directors, employees, or agents did not hire any security guards or security company to provide security at the property at 2012 N SurfRd, Hollywood, FL. 7. On January 5,2021, the exterior surveillance cameras for the property at 2012 N Surf Rd, Hollywood, FL were not operable. 8. On January 5, 2021, Joy Furer was a lawful invitee at the property at 2012 N Surf Rd, Hollywood, FL.