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Filing# 177057784 E-Filed 07/10/2023 03:32:02 PM
INTHE CIRCUIT COURT FOR THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JOY FURER, CASE NO.: CACE-21-016578
Plaintiff,
V.
GG RE HOLLYWOOD BEACH 613 LLC,
and RELAXPRO, LLC,
Defendants.
1
PLAINTIFF'S AMENDED WITNESS LIST
COMES NOW, Plaintiff, JOY FURER, by and through her undersigned counsel,
submits the following Amended Witness List:
1. All parties to this lawsuit and any representative thereof.
2. All witnesses listed in Defendants' Witness List.
3. Joy Furer
c/o Daniel W. Courtney, P.A.
10800 Biscayne Blvd.
Suite700
Miami, FL 33161
4. G.L. Kastner
3250 Hollywood Blvd
Holly-wood, FL 33021
This officer was at the scene of the subject incident is expected to testify to Plaintiffs
police report, authenticity, and findings contained therein.
5. L. Kimble
3250 Hollywood Blvd
Holly-wood, FL 33021
This officer was at the scene of the subject incident is expected to testify to Plaintiffs
police report, authenticity, and findings contained therein.
6. N. Nembhar
3250 Hollywood Blvd
Holly-wood, FL 33021
1
10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055
www. danielcourtneylaw. com dc@danielcourtneylaw. com
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/10/2023 03:31:48 PM.****
This officer was at the scene of the subject incident is expected to testify to Plaintiffs
police report, authenticity, and findings contained therein.
7. C. Rivas
3250 Hollywood Blvd
Holly-wood, FL 33021
This officer was at the scene of the subject incident is expected to testify to Plaintiffs
police report, authenticity, and findings contained therein.
8. A. Zeidell
3250 Hollywood Blvd
Holly-wood, FL 33021
This officer was at the scene of the subject incident is expected to testify to Plaintiffs
police report, authenticity, and findings contained therein.
9. W. Mays
3250 Hollywood Blvd
Holly-wood, FL 33021
This officer is expected to testify to Plaintiffs police report, authenticity, and findings
contained therein.
10. Kristopher Doyle
3250 Hollywood Blvd
Holly-wood, FL 33021
Detective Doyle is expected to testify to Plaintiffs police report, authenticity, and
findings contained in his investigation.
11. Elizabeth Lana
2741 Stirling Rd
Fort Lauderdale, FL 33312
This EMT-Paramedic at the scene of the subject incident is expected to testify to
Plaintiffs EMS report, authenticity, and findings contained therein.
12. Christopher Cortello Jr.
2741 Stirling Rd
Fort Lauderdale, FL 33312
2
10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055
www. danielcourtneylaw. com dc@danielcourtneylaw. com
This EMT-Paramedic at the scene of the subject incident is expected to testify to
Plaintiffs EMS report, authenticity, and findings contained therein.
13. Dustin Cates
2741 Stirling Rd
Fort Lauderdale, FL 33312
This EMT-Paramedic at the scene of the subject incident is expected to testify to
Plaintiffs EMS report, authenticity, and findings contained therein.
14. Viktor Goldenberg
c/o Defendant's Counsel for GG RE Hollywood Beach 613 LLC
2650 North Military Trail, Suite 430
Boca Raton, Florida 33341
Mr. Goldenberg is expected to testify to his knowledge regarding GG RE Holly-wood
Beach 613 LLC's Management Agreement with Neptune Hotel, allegations in Plaintiffs
Complaint, and defenses to Plaintiffs Complaint.
15. Shahar Goldboim
c/o Defendant's Counsel for Relaxpro, LLC
1200 Weston Road, Penthouse
Weston, Florida 33326
Mr. Goldboim expected to testify to his knowledge regarding GG RE Holly-wood Beach
is
613 LLC's Management Agreement with Neptune Hotel, allegations in Plaintiffs
Complaint, and defenses to Plaintiffs Complaint.
16. Myron Melekson
c/o Defendant's Counsel for Relaxpro, LLC
1200 Weston Road, Penthouse
Weston, Florida 33326
Mr. Melekson is expected to testifyto his knowledge regarding GG RE Hollywood Beach
613 LLC's Management Agreement with Neptune Hotel, allegations in Plaintiffs
Complaint, and defenses to Plaintiffs Complaint.
17. Paulo Mure
c/o Defendant's Counsel for Relaxpro, LLC
1200 Weston Road, Penthouse
Weston, Florida 33326
Mr. Mure is expected to testify to his knowledge of the subject location and management.
3
10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055
www. danielcourtneylaw. com dc@danielcourtneylaw. com
18.Tsolo Dakov
c/o Defendant's Counsel for Relaxpro, LLC
1200 Weston Road, Penthouse
Weston, Florida 33326
Mr. Dakov is expected to testify to
knowledge regarding liability.
19.Tyrance McCall
1061 NlM 196th Street
Miami, FL 33169
Mr. McCall is expected to testify to his knowledge of the subject location, including but
not limited to patrolling and security.
20.Thomas Defelice, RN
3501 Johnson St.
Hollywood, FL 33021
Mr. Defelice expected to testify to Plaintiffs medical records, authenticity, medical
is
care, and/or treatment of Plaintiff.
21.Diab Diab, M.D.
3501 Johnson St.
Hollywood, FL 33021
Dr. Diab is expected to testify to Plaintiffs medical records, authenticity, medical care,
and/ or treatment of Plaintiff.
HYBRID WITNESSES
22.Dr.Adam Lynn
Manhattan Psychological PLLC
1910 Pellham Parkway South
Bronx, New York 10461
Dr. Lynn sustained serious injuries as a result of the subject
will testify that Plaintiff
incident and will offer opinions regarding Plaintiffs diagnosis, prognosis, and future
medical care.
23. Raz Winiarsky, M.D.
1414 Newkirk Avenue
Brooklyn, NY 11226
4
10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055
www. danielcourtneylaw. com dc@danielcourtneylaw. com
Dr. Winiarsky will testify that Plaintiff sustained serious injuries as a result of the
subject incident and will offer opinions regarding Plaintiffs diagnosis, prognosis, and
future medical care.
24.Any and all records custodians.
25. All of Plaintiffs treating physicians (including but not limited to radiologists).
26. Any and all persons involved in the prosecution of the assailants from the subject
incident.
27.Any and all impeachment and/or rebuttal witnesses.
28. All persons whose depositions have been taken in this action.
29. Any and all witnesses who have not been uncovered by discovery to date.
30. Any and all persons/entities issued subpoenas in this action.
31. Any and all expert witnesses identified by Defendants without waiving its
objections thereto.
32. Any and all witnesses deposed or identified in depositions or statements.
33.Any and all persons named in Answers to Interrogatories and/or in response to
Request for Production which have been served in this cause or will be served
prior to trial.
34. Plaintiff does not waive her objections to any witness or witnesses being called by
Defendants in this matter.
35. Plaintiff still treating for her injuries
is and thus may disclose additional
physicians in the future.
36. Plaintiff reserves the right to add any witness or witnesses not listed herein but
discovered prior to trial.
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5
10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055
www. danielcourtneylaw. com dc@danielcourtneylaw. com
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was filed via
the Florida Courts E-filing E-portal on to: Amanda N. Rumker, Esq., John J. Glenn,
Esq., ANDERSONGLENN LLP, 2650 North Military Trail, Suite 430, Boca Raton, Florida
33341 at arumker@asglaw.com; andjglenn@asglaw.com, (Counsel for GG RE Hollywood
Beach 613 LLC) and Alicia M. Corbo, Esq., Eric C. Sage, Esq., Mitrani, Rynor, Adamsky
& Toland, P.A., 1200 Weston Road, Penthouse, Weston, Florida 33326 at
acorbo@mitrani.com; and esage@mitrani.com, (Counsel for Relaxpro, LLC) on this 10th
day of July, 2023.
DANIEL W. COURTNEY, P.A
10800 Biscayne Blvd.
Suite 700
Miami, Florida 33161
Telephone: (305) 579-0008
Facsimile: (305) 563-7055
By: s / Daniel W. Courtney
Daniel W. Courtney
Florida Bar No: 0499781
dc@danielcourtneylaw.com
6
10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055
www. danielcourtneylaw. com dc@danielcourtneylaw. com
Preview
Filing# 177057784 E-Filed 07/10/2023 03:32:02 PM INTHE CIRCUIT COURT FOR THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JOY FURER, CASE NO.: CACE-21-016578 Plaintiff, V. GG RE HOLLYWOOD BEACH 613 LLC, and RELAXPRO, LLC, Defendants. 1 PLAINTIFF'S AMENDED WITNESS LIST COMES NOW, Plaintiff, JOY FURER, by and through her undersigned counsel, submits the following Amended Witness List: 1. All parties to this lawsuit and any representative thereof. 2. All witnesses listed in Defendants' Witness List. 3. Joy Furer c/o Daniel W. Courtney, P.A. 10800 Biscayne Blvd. Suite700 Miami, FL 33161 4. G.L. Kastner 3250 Hollywood Blvd Holly-wood, FL 33021 This officer was at the scene of the subject incident is expected to testify to Plaintiffs police report, authenticity, and findings contained therein. 5. L. Kimble 3250 Hollywood Blvd Holly-wood, FL 33021 This officer was at the scene of the subject incident is expected to testify to Plaintiffs police report, authenticity, and findings contained therein. 6. N. Nembhar 3250 Hollywood Blvd Holly-wood, FL 33021 1 10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055 www. danielcourtneylaw. com dc@danielcourtneylaw. com *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/10/2023 03:31:48 PM.**** This officer was at the scene of the subject incident is expected to testify to Plaintiffs police report, authenticity, and findings contained therein. 7. C. Rivas 3250 Hollywood Blvd Holly-wood, FL 33021 This officer was at the scene of the subject incident is expected to testify to Plaintiffs police report, authenticity, and findings contained therein. 8. A. Zeidell 3250 Hollywood Blvd Holly-wood, FL 33021 This officer was at the scene of the subject incident is expected to testify to Plaintiffs police report, authenticity, and findings contained therein. 9. W. Mays 3250 Hollywood Blvd Holly-wood, FL 33021 This officer is expected to testify to Plaintiffs police report, authenticity, and findings contained therein. 10. Kristopher Doyle 3250 Hollywood Blvd Holly-wood, FL 33021 Detective Doyle is expected to testify to Plaintiffs police report, authenticity, and findings contained in his investigation. 11. Elizabeth Lana 2741 Stirling Rd Fort Lauderdale, FL 33312 This EMT-Paramedic at the scene of the subject incident is expected to testify to Plaintiffs EMS report, authenticity, and findings contained therein. 12. Christopher Cortello Jr. 2741 Stirling Rd Fort Lauderdale, FL 33312 2 10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055 www. danielcourtneylaw. com dc@danielcourtneylaw. com This EMT-Paramedic at the scene of the subject incident is expected to testify to Plaintiffs EMS report, authenticity, and findings contained therein. 13. Dustin Cates 2741 Stirling Rd Fort Lauderdale, FL 33312 This EMT-Paramedic at the scene of the subject incident is expected to testify to Plaintiffs EMS report, authenticity, and findings contained therein. 14. Viktor Goldenberg c/o Defendant's Counsel for GG RE Hollywood Beach 613 LLC 2650 North Military Trail, Suite 430 Boca Raton, Florida 33341 Mr. Goldenberg is expected to testify to his knowledge regarding GG RE Holly-wood Beach 613 LLC's Management Agreement with Neptune Hotel, allegations in Plaintiffs Complaint, and defenses to Plaintiffs Complaint. 15. Shahar Goldboim c/o Defendant's Counsel for Relaxpro, LLC 1200 Weston Road, Penthouse Weston, Florida 33326 Mr. Goldboim expected to testify to his knowledge regarding GG RE Holly-wood Beach is 613 LLC's Management Agreement with Neptune Hotel, allegations in Plaintiffs Complaint, and defenses to Plaintiffs Complaint. 16. Myron Melekson c/o Defendant's Counsel for Relaxpro, LLC 1200 Weston Road, Penthouse Weston, Florida 33326 Mr. Melekson is expected to testifyto his knowledge regarding GG RE Hollywood Beach 613 LLC's Management Agreement with Neptune Hotel, allegations in Plaintiffs Complaint, and defenses to Plaintiffs Complaint. 17. Paulo Mure c/o Defendant's Counsel for Relaxpro, LLC 1200 Weston Road, Penthouse Weston, Florida 33326 Mr. Mure is expected to testify to his knowledge of the subject location and management. 3 10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055 www. danielcourtneylaw. com dc@danielcourtneylaw. com 18.Tsolo Dakov c/o Defendant's Counsel for Relaxpro, LLC 1200 Weston Road, Penthouse Weston, Florida 33326 Mr. Dakov is expected to testify to knowledge regarding liability. 19.Tyrance McCall 1061 NlM 196th Street Miami, FL 33169 Mr. McCall is expected to testify to his knowledge of the subject location, including but not limited to patrolling and security. 20.Thomas Defelice, RN 3501 Johnson St. Hollywood, FL 33021 Mr. Defelice expected to testify to Plaintiffs medical records, authenticity, medical is care, and/or treatment of Plaintiff. 21.Diab Diab, M.D. 3501 Johnson St. Hollywood, FL 33021 Dr. Diab is expected to testify to Plaintiffs medical records, authenticity, medical care, and/ or treatment of Plaintiff. HYBRID WITNESSES 22.Dr.Adam Lynn Manhattan Psychological PLLC 1910 Pellham Parkway South Bronx, New York 10461 Dr. Lynn sustained serious injuries as a result of the subject will testify that Plaintiff incident and will offer opinions regarding Plaintiffs diagnosis, prognosis, and future medical care. 23. Raz Winiarsky, M.D. 1414 Newkirk Avenue Brooklyn, NY 11226 4 10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055 www. danielcourtneylaw. com dc@danielcourtneylaw. com Dr. Winiarsky will testify that Plaintiff sustained serious injuries as a result of the subject incident and will offer opinions regarding Plaintiffs diagnosis, prognosis, and future medical care. 24.Any and all records custodians. 25. All of Plaintiffs treating physicians (including but not limited to radiologists). 26. Any and all persons involved in the prosecution of the assailants from the subject incident. 27.Any and all impeachment and/or rebuttal witnesses. 28. All persons whose depositions have been taken in this action. 29. Any and all witnesses who have not been uncovered by discovery to date. 30. Any and all persons/entities issued subpoenas in this action. 31. Any and all expert witnesses identified by Defendants without waiving its objections thereto. 32. Any and all witnesses deposed or identified in depositions or statements. 33.Any and all persons named in Answers to Interrogatories and/or in response to Request for Production which have been served in this cause or will be served prior to trial. 34. Plaintiff does not waive her objections to any witness or witnesses being called by Defendants in this matter. 35. Plaintiff still treating for her injuries is and thus may disclose additional physicians in the future. 36. Plaintiff reserves the right to add any witness or witnesses not listed herein but discovered prior to trial. I I I I 5 10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055 www. danielcourtneylaw. com dc@danielcourtneylaw. com CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was filed via the Florida Courts E-filing E-portal on to: Amanda N. Rumker, Esq., John J. Glenn, Esq., ANDERSONGLENN LLP, 2650 North Military Trail, Suite 430, Boca Raton, Florida 33341 at arumker@asglaw.com; andjglenn@asglaw.com, (Counsel for GG RE Hollywood Beach 613 LLC) and Alicia M. Corbo, Esq., Eric C. Sage, Esq., Mitrani, Rynor, Adamsky & Toland, P.A., 1200 Weston Road, Penthouse, Weston, Florida 33326 at acorbo@mitrani.com; and esage@mitrani.com, (Counsel for Relaxpro, LLC) on this 10th day of July, 2023. DANIEL W. COURTNEY, P.A 10800 Biscayne Blvd. Suite 700 Miami, Florida 33161 Telephone: (305) 579-0008 Facsimile: (305) 563-7055 By: s / Daniel W. Courtney Daniel W. Courtney Florida Bar No: 0499781 dc@danielcourtneylaw.com 6 10800 Biscayne Blvd. Suite 700 Miami, FL 33161 Tel: (305)579-0008 Fax: (305)563-7055 www. danielcourtneylaw. com dc@danielcourtneylaw. com