Motion to Strike in Joy Furer Plaintiff vs. GG RE Hollywood Beach 613 LLC, et al Defendant| Trellis.Law

On August 31, 2021 a Motion,Ex Parte 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.

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Filing# 180032226 E-Filed 08/18/2023 06:23:45 PM

IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA

CASE NO.: CACE-21-016578

JOY FURER

Plaintiff.

GG RE HOLLYWOOD BEACH 613 LLC,
And RELAXPRO, LLC,

Defendants.
'

DEFENDANT'SDAUBERTMOTION
TO EXCLUDE PLAINTIFF'S TREATING PHYSICIAN, ADAM LYNN, PSY. D., FROM
OFFERING EXPERT TESTIMONY AT TRIAL

Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through the undersigned

counsel, hereby moves for an order precludingPlaintiff's treatingphysician,Adam Lynn, Psy.

D., from offeringexpert testimony at trial,
and in support thereof states:

INTRODUCTION

1. Plaintiff's treatingpsychologist,Dr. Adam Lynn, should not be permitted to

before the jury in
testify this case because his opinionsdo not meet the minimum requirementsof

Daubert. Dr. Lynn intends to tell a jury that Plaintiff suffers from post-traumatic
stress disorder

("PTSD") as a result of the assault that is the subjectof this case. However, Dr. Lynn's opinion

relies on inaccurate and incomplete information shared to him by the Plaintiff. Namely, that

Plaintiff had no prior psychologicalissues before the subject incident, and that all of the

symptomology she expressed to Dr. Lynn began after the subjectincident.

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/18/2023 06:23:45 PM.****
2. Discovery in this case has revealed the information that Dr. Lynn relied on his

forming his opinions is false. Plaintiff has a long historyof psychologicalissues. Since 2005,

Plaintiff has treated with at least thirteen (13) mental healthcare providers. She has been

diagnosed with and taken medications for generalizedanxiety,social anxiety,major depressive

disorders,insomnia, panic attacks,and even PTSD (thecondition she claims was caused by the

subjectincident).Beyond her confirmed diagnosis of PTSD, in 2019, only two years before the

subjectincident, Plaintiff also testified under oath that she suffered from major PTSD. The

symptoms she described at that time mirror the ones she described to Dr. Lynn following the

subjectincident.

3 Dr. Lynn was completelyunaware o f Plaintiff's psychologicalissues and made no

efforts to ascertain this information before tellinga jury that Plaintiff suffers from PTSD which

is causallyrelated to the subjectincident. Dr. Lynn testified that had never reviewed any of

Plaintiff's prior medical or mental health records that pre-dated or post-dated the subject

incident. He was unaware that Plaintiff had previously testified that she suffered from major

PTSD, that she had previouslybeen diagnosed with PTSD or any of the other litanyof mental

health disorders that she has been diagnosed with, that she previouslytreated with thirteen (13)

other mental healthcare providers,and that she had taken various medications only prescribedfor

mental health conditions,well before the subjectincident took place.

4. In Florida, it is axiomatic that a testifyingexpert's opinions must be reliable in

order to be presentedto the jury.Dr. Lynn's opinionssimply cannot be considered reliable when

they are based on falsehoods. The court cannot permithim to testify.

FACTUAL BACKGROUND

2
5. Plaintiff allegesthat on January 5, 2021, she was ambushed and carjackedby two

individuals while walking to her car in the employee parking lot of the Defendant's hotel. See

Plaintiff's Second Amended Complaint.

6. Following the incident,Plaintiff began treatingwith Dr. Adam Lynn, a clinical

psychologistin New York. See Trial Deposition of Adam Lynn, Psy.D., dated July 21, 2023, at

4:1-2; 65:1-5, attached hereto as Exhibit A.

7. Dr. Adam Lynn testified that when he first met Plaintiff on January 14, 2021, she

was in an acute state of post-traumaticstress. Id at 8:22-25. He explained that the subject

incident had occurred recently,and that Plaintiff had symptomology of panic symptoms,

shortness of breath, heart palpitations,
flashbacks, nightmares, intrusive negative thoughts,

concerns for her welfare, and hypervigilance,which Dr. Lynn said were textbook symptoms of

PTSD. Id. at 9: 10-19.

8 Dr. Lynn was not sure if there was a difference between someone who has PTSD

and someone who exhibits PTSD symptoms. Id. at 20-23. Nonetheless, Dr. Lynn testified that he

diagnosed Plaintiff with PTSD. Id. at 9:24-10:2. Dr. Lynn testified that Plaintiff met the criteria

for diagnosingher with PTSD based on the symptoms that she described to him. U. at 10:3-8.

9- When asked whether Plaintiff's PTSD was caused by the subjectincident,Dr.

Lynn testified that it was causallyrelated,statingspecifically:

A: According to her, she did not have the symptoms that she presented to
me on January 14th,and since then, priorto this incident.
Q: And so, if what she--
A: According to her-- according to her report, this incident
preceded and precipitatedthe symptomology that she presentedto me.
Q: And do you have any reason otherwise, uh, to believe that something
else would have caused her, uh, PTSD symptomatology?
A: No.

Id.at 13:2-15 (emphasisadded).

3
10. Dr. Lynn was questioned about other events that could have contributed to

Plaintiff's PTSD. He opined that while Plaintiff had experiencedother "difficult life events", the

severityof the symptomology that she presented to him in January of 2021, did not seem to be

he testified:
the result ofthose other incidents. Specifically,

Q: Okay. And, you know, um, there's evidence in this case, that Ms. Furer
had other, um, traumatic events in her life. It-- it could be other
accidents, it could be loss of a parent, a lot of different things.Is it
reasonable to conclude that,uh, the loss of her parents, for example,
or, an automobile accident,would have caused her PTSD?
A: In opinion,those were difficult life events for her. As I-- that the
my
severityof the symptomology that she presented to me in January of
2021 does not seem to be the result of those other incidents.

Id at. 12:16-25.

11. although Dr. Lynn states that the "difficult
Interestingly, life events" did not

"seem" to cause the PTSD symptoms Plaintiff was complaining of, evidence uncovered in this

case reveals that in fact,Plaintiff herself claimed to have suffered from major PTSD as a result

of one of those "difficult life events" - a car accident in 2015. See Deposition of Plaintiff,
Joy

Furer, dated January 31, 2019, attached hereto as Exhibit B, at 96:7-13.

12. Moreover, Plaintiff's self-reportedsymptomology, which Dr. Lynn testified

supported his diagnosis of PTSD as it relates to the subjectincident,is almost exactlythe same

as the symptomology that Plaintiff claimed as a result ofher 2015 car accident. Id.

in 2019 -4
13. Specifically, years after the car accident that Plaintiff herself testified

caused her to suffer from major PTSD - Plaintiff testified that because of the car accident she

was "feelingvery depressed,was having flashbacks, waking up at night,[I was having a hard

time gettingback in the car to drive,... was having major [PTSDI, ... couldn't sleep."Id.

Plaintiff testified that her emotional issues that she was in and out of psychological
persisted,

treatment, and that she was still going through "continuous U.
pain and suffering." at 98:6-18.

4
14. During his treatment of Plaintiff and at the time of his trial deposition,Dr. Lynn

was under the impressionthat Plaintiff had no priorhistoryof mental illness. Id at 34:19-22. Dr.

Lynn testified that Plaintiff to him that she had no historyof mental
self-reported illness. Id. at

34:23-25.

15. Dr. Lynn testified that he was unaware that priorto the subjectincident Plaintiff

claimed that she suffered from major PTSD. Id at 36:2-14. He was also unaware that she had

been diagnosed with depressionas a result of the car accident from 2015. Id. at 36:15-37:10.

Plaintiff failed to tell him about her pre-incidenttreatment with other mental health care

Id
providers. at 41: 11-18.

16. Dr. Lynn never reviewed any of Plaintiff's medical or mental health records from

either before or after the subjectincident to verify Plaintiff's statements. Id at 35:1-14. This is

especiallyconcerning because in order to diagnose someone with PTSD, as agreed to by Dr.

Lynn, their symptoms cannot be the result of "substance use, medication reaction,or other type

of illness." Id. at 31:7-11-32:5.

17. Had Dr. Lynn reviewed any of Plaintiff's priormedical or mental health records,

or had Plaintiff been honest with Dr. Lynn, he would have realized that Plaintiff has long

suffered from the psychologicalissues she now attributes to the subjectincident
- including

PTSD. See forthcomingcitations.

18. Discovery has revealed that Plaintiff has treated with at least thirteen (13) other

medical professionals
or facilities for her mental health - Dr. Johanna Tiemann, Dr. Allen Geller,

Dr. Ellen Blye, Dr. Elliot Arons, Dr. Ingrid Kemperman, Joan Klein, LCSW, Lynn Beth

Schneider, LCSW, Lyudmila Krupitsky,LCSW, Dr. Inna Yuryev-Golger, Ohel Children's Home

and Family Services, the National Drug Abuse Association, InterboroughDevelopmental &

5
Consultation Center, at least one unknown physician,1
None of these providerswere disclosed to

Defendants or to Dr. Lynn.

19. Defendant only has records from Walgreens, New York Medicaid (of which

Defendant only received half of the 147 pages of recordsj,and Dr. johanna Tiemann. Those

records show that in 2005, Plaintiff treated with Ms. Klein for Diagnosis Code 300.02
-

Generalized Anxiety Disorder. See New York Medicaid Records, attached hereto as Exhibit C.

Also in 2005, Plaintiff treated with Dr. Arons Diagnosis Code 300.0
Elliot for - State.
Anxiety

Icl. In 2007, Plaintiff treated with Ms. Schneider for Diagnosis Code 309.81-PTSD.Icl.

20. In 2011 and 2012, Plaintiff filled prescriptions
for Venlafaxine and Alprazolam

(Xanax). See Walgreen's Pharmacy Records, attached hereto as Exhibit D. Venlafaxine is an

used to treat major depressive disorder and social anxiety disorder.2 Xanax
anti-depressant is

3
used to treat acute generalizedanxietydisorder and panic disorder.

21. A few years later,in April and May of 2015, Plaintiff treated with the

National Association of Drug Abuse for an unspecified reason. See Exhibit C. A few months
after that, on July 16, 2015, Plaintiff filled for Zolpidem (Ambien), Mirtazpine
prescriptions

(Remeron), and Clonazepam (Klonopin). Zolpidem (Ambien) is used to treat insomnia#,

used to
Mirtazapine is an anti-depressant treat and Klonopin
major depressivedisorder5, is a

v6
sedative used to treat panic disorder and seizures' . See Exhibit D.

1
She was also referred to a psychiatrist,Dr. Irina Kiblistsky,but Dr. Kiblistsky'spracticehas since been closed, so
Defendant has not been able to confirm whether Plaintiff treated with Dr. Kiblistsky.
2
See U.S. Food and Drug Administration, Full PrescribingInformation on Venlafaxine Extended Release Tablets,
Section 1 Indication and Usage, attached hereto as Exhibit E.
See U.S. Food and Drug Administration, Full PrescribingInformation on Xanax, Indications and Usage, Page 4,
3

attached hereto as Exhibit F.
4
See U.S. Food and Drug Administration, Full Prescribing Information on Ambien (zolpidem tablets), Section 1:
Indications and Usage, Page 2, attached hereto as Exhibit G.
5
See U.S. Food and Drug Administration, Full PrescribingInformation on Remeron (mirtazapine),Indications and
Usage, Page 6, attached hereto as Exhibit H.
6
See U.S. Food and Drug Administration, Rx Only, Klonopin, Indications and Usage, Page 2, attached hereto as
Exhibit I.

6
22. In 2016, Plaintiff treated with Ohel Children's Home and Family Services, a

for Diagnosis Code F064
mental health facility, -
Anxiety Disorder. See Exhibit C. In 2016-

2017, Plaintiff treated with an unknown physician for Diagnosis Code F313 B*olar Disorder,

Current Episode Depressed, Mild or Moderate Severity,and Diagnosis Code F411 - Generalized

Anxiety Disorder. Id.

23. In 2016-2017, Plaintiff also treated with Ms. Kruptisky for Diagnosis Code

F317.1 BipolarDisorder. U. In 2016, Plaintiff filled an
- for Escitalopram, anti-
multiplescripts

depressant.Id. In 2017, Plaintiff treated with Dr. Inna Yuryev-Golger, a psychiatrist,
for

Diagnosis Code 411 Generalized Anxiety Disorder. Id. In
-
2017, Plaintiff filled prescr*tionsfor

Sertraline (Zoloft)a medication to treat mental health disorders. Id. In 2018, Plaintiff treated at

the Interborough Developmental & Consultation Center, which is a mental health care provider,

for Diagnosis Code F432.2
- Adjustment Disorder with Anxiety. Plaintiff also filled a

for Lorazepam on November 16, 2018, which
prescription is used to treat "excessive anxiety."

See Exhibit D.

24. Dr. Lynn did not have any of the foregoing information when he treated the

or
Plaintiff, when he sat for his trial depositiontestimony on July 21, 2023. See Exhibit A at

34: 19-25 (wherein Dr. Lynn testifies that he believed Plaintiff had no historyof mental health

issues based on her self-report).

25. While Dr. Lynn would not admit that his lack of information on Plaintiff's prior

mental health precludedhim from relating
her PTSD to the subjectincident (he skirted the issue),

he did admit that in order to be diagnosed with PTSD related to a specificevent, the

symptomology cannot have been caused by something else. Id at. 32:2-5; 43:17-48:2.

7
26. Based on common sense, Dr. Lynn cannot say that Plaintiff's symptoms are not

the cause of something else because he admittedly had no information whatsoever about

Plaintiff's mental health history- a historythat includes a former PTSD diagnosis,personality

disorder diagnoses,and treatment with a drug abuse association.

27. Simply put, Dr. Lynn's opinions are not reliable because they are based on

incomplete and inaccurate information shared (or not shared) with him by the Plaintiff that he

failed to verifyby reviewing even a singlerecord related to Plaintiff's priormental or medical

health history.

MEMORANDUM OF LAW
I. Legal Standard

In Florida,Daubert is based on Fla. Stat. § 90.702
- Testimony by experts:

"-- If scientific,technical,or other will assist the trier
knowledge
specialized
of fact in understanding the evidence or in determining a fact in issue, a
witness qualifiedas an expert by knowledge, skill,experience,training,or
education may testifyabout it in the form of an opinion or otherwise, if:
(1)The testimony is based upon sufficient facts or data;
(2)The testimony is the productof reliable princ*lesand methods; and
(3)The witness has appliedthe principles and methods reliablyto the facts
..
of the case.

The Preamble to the Bill (Ch. 2013-107, H.B. 7015) expresslystates that by amending Fla. Stat.

§ 90.702, the Florida Legislatureintended to "adopt the standards for expert testimony in the

courts of this state as provided in Daubert v. Merrell Dow Pharmaceuticals, Inc.,509 U.S. 579

(1993),General Electric Co. v. Joiner, 511 -U.S. 136 (1997), and Kumho Tire Co. v. Carmichael,

526 U.S. 137 (1999);"and "prohibitin the courts of this state pure opiniontestimony",adopting

Marsh v. Falyou, 977 So.2d 543 (Fla.2007).

8
The most important practicaldifference between Daubert and Frye is that Daubert

appliesto all expert testimony. "Thus, the Daubert test appliesnot only to 'new or novel'

scientific evidence, but to all other expert opinion testimony. Expert testimony that might

The legislative
otherwise qualifyas "pure opinion"testimony is expresslyprohibited. purpose of

the new law is clear: to of expert testimony in the courts of this
tightenthe rules for admissibility

state." Perez v. Bell South Telecom. Inc., 138 So.3d 492, 497 (Fla.3d DCA 2014) (affirming

exclusion of expert who testified that workplace stress caused a placentalabruption).

Given its recent applicationin Florida, the applicationof Daubert in Federal Courts is

The admission of expert evidence
appropriate. is governed by Federal Rule of Evidence, 702, as

explainedby Daubert and its progeny. See Daubert v. Merrell Dow Pharmaceuticals, Inc.,509

U.S. 579 (1993); Kumho Tire Company, Ltd. v. Carmichael, 526 U.S. 137 (1999). Fed. R. Evid.

702 states that technical,or other specializedknowledge will
"[i]fscientific, assist the trier of

fact to understand the evidence or to determine a fact in issue,a witness qualifiedas an expert by

thereto in the form of an opinion
or education, may testify
knowledge, skill,experience,training,

or otherwise." City of Tuscaloosa v. Harcros Chems., 158 F. 3d 548,553 (llth
Cir. 1998).

Under Rule 702 and Daubert, district courts are charged as "gatekeepers"which admit

expert testimony only if it is both reliable and relevant. See Daubert, 509 U.S. at 589. District

Courts are charged with this gatekeepingfunction "to ensure that speculative,
unreliable expert

testimony does not reach the jury" under the mantel of reliability
that accompanies the

designation"expert testimony." See also, Kumho Tire Co. Ltd. v. Carmichael, 516 lj.S. 137,

147; Johnson & Johnson Vision Care, Inc. v. CIBA Vision Corp., 616 F. Supp. 2d 1250, 1256

(M.D. Fla. 2009).

9
In deciding on the admissibility
of expert testimony,district courts should engage in a

rigorousinquiryto determine whether expert testimony is admissible. In doing so, evidence may

only be admitted if.

"(1)the expert is qualified to testifycompetentlyregardingthe matters to address;
(2) the methodology by which the expert reaches his conclusions is sufficiently
reliable as determined by the sort of inquirymandated in Daubert; and (3) the

testimony assists the trier of fact,through the applicationof scientific,
technical,
or specializedexpertise,to understand the evidence or to determine a fact in
..
issue.

ciiyof Tuscaloosa v. Harcros Chems., Inc.,158 F. 3d 548, 562 (llth
Cir. 1998).

The party offeringthe expert testimony has the burden of satisfyingeach of these three

elements by a preponderance of the evidence. See Allison v. McGhan Med Corp., 184 F. 3d

1300,1306 (llthCir. 1999).

II. Dr. Lynn's Opinions Are Not Reliable.

In inquiry,the Court must independentlyanalyze each
making a reliability step in the

analysisleading to the expert'sultimate conclusions and determine whether each step supports

the conclusion. If the Court determines that any step in the expert'schain of logicis unreliable,

the expert'stestimony is rendered inadmissible. McClain v.
Metabolife Int'l Inc.,401 F 1d 1233,

1245 (llth Cir. 2005). Scientific knowledge must be the subjectof the expert'stestimony,which

is an inference or assertion "derived by the scientific method" Perez at 497. Under this standard

..
the "pure opinion testimony of someone otherwise qualifiedas an expert is inadmissible in the

State of Florida. Id.

"Pure Opinion" testimony is "based only on clinical experienceand training;
in contrast,

the cornerstone of section 90.702 is relevance and reliability
based on scientific knowledge."

Booker v. Sumter County Sher#fs Q#ice/N. Am. Risk Services, 166 So.3d 189, 194 (Fla. 1st

DCA 2015). Courts will exclude causation opiniontestimony,where an expert has based their

10
..

opinion on a plaintiffs'
account "without consideration of other possiblecauses of an injury".

Carmody v. State Farm Mut. Auto. Ins. Co., 6:14-CV-830-ORL-37, 2015 WL 5542534, at *3

(M.D. Fla. Sept. 18, 2015). A treatingphysician is allowed to express a lay opinion, but any

opinion expressed by the physician outside of treatment based on scientific,technical or

knowledge
specialized is expert testimony,subjectto the rigorsand examination under Daubert.

Wilson v. Taser Intern., Inc.,303 Fed. Appx. 708, 712 (llth Cir. 2008).

Under a Daubert analysisone cannot make an inference that "a temporal relationship

McClain at 1243. Simply because an incident occurs, and one
proves a causal relationship."

subsequentlyclaims a health condition or injury,does not prove causation simply because after

one, came the other. Id. A simple conclusion that a person does not manifest until
injuries after

an incident is a fallacywhich assumes causation from a temporal sequence. Cooper at 967. Even

priorto the adoption of the Daubert standard,courts in Florida have found that causation theories

between the incident in question and the resulting
based solely on the temporal relationship

injuryare not methodologically sound. See Cerna v. S. Florida Bioavailability
Clinic, Inc.,815

So. 2d 652,656 (Fla.3d DCA 2002), cause dismissed, 831 So. 2d 671 (Fla.2002).

Dr. Lynn's opinionsregarding causation in this matter do not rest upon any substantive

between his understandingof Plaintiffs allegations
basis other than the temporal relationship and

complaints following the incident in question.As such, his opinions do not meet the strict

under Florida Rule of Evidence 90.702 and Daubert.
standard for admissibility

Succinctly,the basis for Dr. Lynn's opinions in this matter can be boiled down to the

following (1) Plaintiff told Dr. Lynn that she was ambushed and assaulted on January 5, 2021,

(2) Plaintiff told Dr. Lynn that she suffers from PTSD as a result ofthe incident,(3) Plaintiff told

Dr. Lynn that she had no historyof mental health issues priorto the incident,(4) Plaintiff told

11
Dr. that she experiencespanic symptoms, shortness of breath, heart palpitations,
flashbacks,

nightmares,intrusive negativethoughts,concerns for her welfare, and hypervigilance,
as a result

of the incident,(5) Plaintiff told Dr. Lynn that she did not experience these symptoms before the

subject incident, and (5) Dr. Lynn was unaware of any other reasons that Plaintiff may be

experiencingthese symptoms.

Almost all of the bases above, used by Dr. Lynn in the formation of his opinions on

incorrect. The heart of Dr. Lynn's causation opinionis that Plaintiff had
causation, are factually

no mental health issues until the subjectincident. This is patently false,and alone renders his

opinion on causation,as unreliable.

The treatment records from before the subjectincident prove that the beliefs Dr. Lynn

had in forming his causation opinions were inaccurate. Dr. Lynn's opinions on the causation of

Plaintiff's between his belief of when the
injuriesare based solelyon the temporal relationship

injuryoccurred, and the subsequent complaints.This clearlydoes not meet the requirementsof

under the Daubert standard (or even the
admissibility less stringentFoe standard),before one

even begins to look at the sheer validityof the opinion itself based on the contradictoryfactual

information available in Plaintiff' s medical records,which Dr. Lynn failed to review.

It is clear that here, Dr. Lynn is presentingtestimonythat has been explicitly
barred under

a Daubert analysis;that of basing his "opinions on a plaintiffs
account of the facts without

consideration of other possible causes of an injury."Carmody at *3. See also Wilson at 714.

("Although a medical expert need not rule out every possible alternative in order to form an

opinion on causation,expert opinion testimony is properlyexcluded as unreliable if the doctor

"engaged in very few standard diagnostic techniques by which doctors normally rule out

alternative causes and the doctor offered no good explanationas to why his or her conclusion

12
remained reliable" or if "the defendants pointed to some likelycause of the plaintiffs
illness

other than the defendants' action and [thedoctor] offered no reasonable explanationas to why he

or she still believed that the defendants' actions were a substantial factor in bringing about that

illness")(emphasis
added).

Here Dr. Lynn's opinion plainlyrejectsthe factual information available to him that

Plaintiff had ongoing mental health issues before the subjectincident. Dr. Lynn's opinions are

See also Kilpatrickv. Breg Inc., 613
directlybased on an impermissibletemporalrelationship.

F.3d 1329, 1343 (llth Cir. 2010) ("Dr.Poehling made clear that he reached his conclusions with

respect to Kilpatrick's
injuries
merely by looking at Kilpatrick'sshoulder before and after the

use of Breg's pain pump. The district court did not abuse its discretion in findingDr. Poehling's

methodology to establish specific causation unreliable under Daubert.3-, McClain at 1243

("simply because a person takes drugs and then suffers an injury does not show causation.

Drawing such a conclusion from temporal relationships
leads to the blunder of the post hoc ergo

proper hoc fallacy.").
Dr. Lynn clearlyfalls into the category of inadmissible testimony where a

physicianhas not examined, ruled out, or even attempted to explain away other alternatives to

their opinion.

Dr. Lynn's causation opinionsregardingany psychologicalinjuryto Plaintiff do not pass

the Daubert standard. His opinionsdo not meet the standards on reliability
and validityto allow

them to be admitted in a Florida Court.

Wherefore, based on the foregoing Defendant, GG RE HOLLYWOOD BEACH 613

LLC, respectfully
requests this Court grant its motion and precludeDr. Lynn from offeringany

testimony at the trial in this matter, and other such relief as the Court deems justand proper.

DATED: 18th day ofAugust, 2023.

13
ANDERSONGLENN LLP
/s/ .John .J. Glenn

John J. Glenn, Esquire
Florida Bar No.. 957860

jglenn@asglaw.com
Amanda N. Rumker, Esquire
Florida Bar No.. 125580

arumker@asglaw. com
2650 N. MilitaryTrial,Suite 430
Boca Raton, Florida 33431
(561) 893-9192 Phone
(561) 893-9194 Fax
CounselMDefendant

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 18th day of August, 2023, I electronically filed the

foregoing document with the Clerk of the Court using Florida Court's E-FilingPortal and certify
that all counsel of record have been served via transmission of Notice of Electronic Filing

generatedby Florida Court E-FilingPortal or in some other authorized manner for those counsel
or who
parties are not authorized to receive Notices of Electronic Filing.
electronically

/s/ .John .J. Glenn

John J. Glenn, Esquire

Case Info

Judge

Frink, Keathan B. Track Judge’s New Case

Case No.

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Document Filed Date

August 18, 2023

Case Filing Date

August 31, 2021

County

Parties

Bodenheimer, Zachary Dylan Attorney for the Plaintiff
Corbo, Alicia Marie Attorney for the Defendant
Courtney, Daniel W Attorney for the Plaintiff
Designedvr Holdings LLC Defendant
Furer, Joy Plaintiff
GG RE Hollywood Beach 613 LLC Defendant
Glenn, John Glenn Attorney for the Defendant
RELAXPRO LLC Defendant
Amanda Rumker Attorney
Scott Orth Attorney
David Henry Attorney
Heather Stover Attorney
David Emas Attorney
NICHOLAS WALTER Attorney
Eric Sage Attorneys for Defendants
Rodney Romano Attorneys for Defendants
Jon Shields Attorneys for Plaintiffs
John Jones Attorneys for Plaintiffs
Eric Giunta Attorney

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Motion,Ex Parte: Joy Furer Plaintiff vs. GG RE Hollywood Beach 613 LLC, et al Defendant

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