On August 31, 2021 a
Party Discovery
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# 175980367 E-Filed 06/23/2023 10:11:59 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.: CACE-21-016578
JOY FURER,
Plaintiff,
V
GG RE HOLLYWOOD BEACH 613 LLC,
and RELAXPRO, LLC,
Defendants.
i
DEFENDANT GG RE HOLLYWOOD BEACH 613 LLC'S
RESPONSE TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION
Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through the undersigned
counsel and pursuant to Rule 1.350 ofthe Florida Rules of Civil Procedure, responds to the Second
JOY
Request for Production propounded by the Plaintiff, FURER, as follows:
PRELIMINARY STATEMENT
1. and development of facts and circumstances relatingto
Defendant's investigation
this matter is ongoing. These responses and objectionsare made without prejudiceto, and are not
a waiver of,this Defendant's rightto relyon other facts or documents at trial.
2. Defendant expresslyreserves the rightto supplement, clarify,
revise,or correct any
or all of the responses and objectionsherein,and to assert additional objectionsor privileges,
in
one or more subsequentsupplementalresponse(s).
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/23/2023 10:11:53 AM.****
RESPONSES TO SECOND REQUEST FOR PRODUCTION
1. Any and all photographs and videotapespertainingto the investigation
and/or surveillance
activityconducted in this cause.
RESPONSE:
See Folder Names Surveillance. (Followed to Plaintiff counsel email).
2. Any and all diaries,reports, time sheets or summaries of the investigationand/or
conducted in this cause.
surveillance activity
RESPONSE:
See Folder Named Surveillance. (Followed to Plaintiff counsel email).
3. Any and all billingrecords, invoices or statements for services and cost prepared in
connection with the investigation/surveillance conducted in this cause.
activity
RESPONSE:
See Folder Named Surveillance. (Followed to Plaintiff counsel email).
4. Any and all documents capturing,disclosing,
depicting,explaining,and/or outliningany
and all details of GG RE Hollywood Beach 613 LLC's ownership ofthe premises located
at 2012 North Surf Road, Hollywood, Florida 33019, effective on or about the day of the
subjectincident.
RESPONSE:
See Folder Named Ownership. (Followed to Plaintiff counsel email).
5. Any and all documents in the possession of and/or accessible to GG RE Hollywood Beach
613 LLC that capture, disclose,depict,explain,and/or outline the physicalparameters of
the subjectproperty located at 2012 North Surf Road, Hollywood, Florida 33019, as was
effective on or about the date ofthe subjectincident.
2
RESPONSE:
See Folder Named Ownership. (Followed to Plaintiff counsel email).
Dated: June 23,2023.
ANDERSONGLENN LLP
/s/.John .J. Glenn
John J. Glenn, Esquire
Florida Bar No.. 957860
jglenn@asglaw.com
Amanda N. Rumker, Esquire
Florida Bar No.: 122580
arumker@asglaw.com
2650 North MilitaryTrail,Suite 430
Boca Raton, Florida 33341
Tel.: (561) 893-9192
Fax: (561) 893-9194
Attorneysfor GG RE Hollywood Beach 613
LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June 23,2023, I electronically
filed the foregoing document
with the Clerk of the Court using Florida Court's E-FilingPortal and certifythat all counsel of
record have been served via transmission ofNotice of Electronic Filinggeneratedby Florida Court
E-Filing Portal or in some other authorized manner for those counsel or partieswho are not
Notices of Electronic Filing.
authorized to receive electronically
/s/.John .J. Glenn
John J. Glenn, Esquire
3
Document Filed Date
June 23, 2023
Case Filing Date
August 31, 2021
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Filing# 175980367 E-Filed 06/23/2023 10:11:59 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-016578 JOY FURER, Plaintiff, V GG RE HOLLYWOOD BEACH 613 LLC, and RELAXPRO, LLC, Defendants. i DEFENDANT GG RE HOLLYWOOD BEACH 613 LLC'S RESPONSE TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through the undersigned counsel and pursuant to Rule 1.350 ofthe Florida Rules of Civil Procedure, responds to the Second JOY Request for Production propounded by the Plaintiff, FURER, as follows: PRELIMINARY STATEMENT 1. and development of facts and circumstances relatingto Defendant's investigation this matter is ongoing. These responses and objectionsare made without prejudiceto, and are not a waiver of,this Defendant's rightto relyon other facts or documents at trial. 2. Defendant expresslyreserves the rightto supplement, clarify, revise,or correct any or all of the responses and objectionsherein,and to assert additional objectionsor privileges, in one or more subsequentsupplementalresponse(s). 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/23/2023 10:11:53 AM.**** RESPONSES TO SECOND REQUEST FOR PRODUCTION 1. Any and all photographs and videotapespertainingto the investigation and/or surveillance activityconducted in this cause. RESPONSE: See Folder Names Surveillance. (Followed to Plaintiff counsel email). 2. Any and all diaries,reports, time sheets or summaries of the investigationand/or conducted in this cause. surveillance activity RESPONSE: See Folder Named Surveillance. (Followed to Plaintiff counsel email). 3. Any and all billingrecords, invoices or statements for services and cost prepared in connection with the investigation/surveillance conducted in this cause. activity RESPONSE: See Folder Named Surveillance. (Followed to Plaintiff counsel email). 4. Any and all documents capturing,disclosing, depicting,explaining,and/or outliningany and all details of GG RE Hollywood Beach 613 LLC's ownership ofthe premises located at 2012 North Surf Road, Hollywood, Florida 33019, effective on or about the day of the subjectincident. RESPONSE: See Folder Named Ownership. (Followed to Plaintiff counsel email). 5. Any and all documents in the possession of and/or accessible to GG RE Hollywood Beach 613 LLC that capture, disclose,depict,explain,and/or outline the physicalparameters of the subjectproperty located at 2012 North Surf Road, Hollywood, Florida 33019, as was effective on or about the date ofthe subjectincident. 2 RESPONSE: See Folder Named Ownership. (Followed to Plaintiff counsel email). Dated: June 23,2023. ANDERSONGLENN LLP /s/.John .J. Glenn John J. Glenn, Esquire Florida Bar No.. 957860 jglenn@asglaw.com Amanda N. Rumker, Esquire Florida Bar No.: 122580 arumker@asglaw.com 2650 North MilitaryTrail,Suite 430 Boca Raton, Florida 33341 Tel.: (561) 893-9192 Fax: (561) 893-9194 Attorneysfor GG RE Hollywood Beach 613 LLC CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 23,2023, I electronically filed the foregoing document with the Clerk of the Court using Florida Court's E-FilingPortal and certifythat all counsel of record have been served via transmission ofNotice of Electronic Filinggeneratedby Florida Court E-Filing Portal or in some other authorized manner for those counsel or partieswho are not Notices of Electronic Filing. authorized to receive electronically /s/.John .J. Glenn John J. Glenn, Esquire 3