Preview
Filing# 175391271 E-Filed 06/15/2023 11:29:20 AM
INTHE CIRCUIT COURT OF THE 17
,TH
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
ANSWERS TO SECOND REQUEST FOR ADMISSIONS FROM PLAINTIFF
Defendant, GG RE HOLLYWOOD BEACH 613 LLC., by and through undersigned
counsel and pursuant to Rule 1.370 ofthe Florida Rules of Civil Procedure, responds to Plaintiff,
JOY FURER'S, Second Request for Admissions Dated May 16, 2023, as follows:
1. On April 29, 2019, GG RE Hollywood Beach 613 LLC was grantedthe Warranty Deed
..
attached hereto as Exhibit "A' for the property located at 2012 North Surf Road,
Hollywood, Florida 33019,
e with the legaldescription:
"Lots 1 through 5, 21 and 22, Block 9 of HOLLYWOOD
BEACH FIRST ADDITION, accordingto the Plat thereof as recorded in Plat Book
1, Page 31, ofthe Public Records of Broward County, Florida."
RESPONSE: Admitted.
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/15/2023 11:29:20 AM.****
2. On January 5, 2021, GG RE Hollywood Beach 613 LLC was the owner of the property
located at 2012 North Surf Road, Hollywood, Florida 33019,
o which has the legal description:
"Lots 1 through 5, 21 and 22, Block 9 of
HOLLYWOOD BEACH FIRST ADDITION, according to the Plat thereof as
recorded in Plat Book 1, Page 31, of the Public Records of Broward County,
..
Florida.'
RESPONSE: Admitted.
3. The document attached as Exhibit "A" is admissible in evidence at the trial of this matter.
RESPONSE: Objection as this request goes beyond the permissiblescope of a Request
for Admission and calls for a legal conclusion.
4. The website, bcpa.net,associated with Marty Kiar, elected Broward County, Florida
Property Appraiser,is a widely accepted web service for determining property boundaries
for propertieslocated within Broward County, Florida,such as the subjectproperty.
RESPONSE: Denied. The website has the following disclaimer: " IMPORTANT 1
DISCLAIMER: This map is maintained for tax roll purposes only and may not be
appropriate for other uses. The Broward County Property Appraiser's Office does
not guarantee or make any representation regarding the information contained
herein. This map is not a substitute for a title search or land survey. This map does
not impact the interests of any person or properties,including any present or future
,,
right or use of real property. Reliance upon this map is at the user's risk.
5. The document attached as Exhibit "B" is an authentic image from bcpa.net.
RESPONSE: Objection as
"-
authentic" is vague and ambiguous. Moreover, the
website has the following disclaimer: "IMPORTANT DISCLAIMER: This map is
2
maintained for tax roll purposes only and may not be appropriate for other uses. The
Broward County Property Appraiser's Office does not guarantee or make any
representation regarding the information contained herein. This map is not a
substitute for a title search or land survey. This map does not impact the interests of
any person or properties,including any present or future right or use of real property.
map is at the user's risk.
,,
Reliance upon this
6. The areas within the red perimetersdepictedin the document attached as Exhibit "B" are
an accurate representationofthe parameters ofthe subjectproperty located at 2012 North
Surf Road, Hollywood, Florida 33019, as was effective on or about the date ofthe subject
incident.
RESPONSE: Admitted.
7. The document attached as Exhibit "B" is admissible in evidence at the trial of this matter.
RESPONSE: Objection as this request goes beyond the permissible scope of a Request
for Admission and calls for a legal conclusion.
8. All of the area wherein Plaintiff allegesthe incident occurred, as described in Plaintiff's
Complaint, is within the parameters of the property located at 2012 North Surf Road,
Hollywood, Florida,33019, with the legaldescription:
"Lots 1 through 5, 21 and 22, Block 9 of HOLLYWOOD BEACH FIRST
ADDITION, accordingto the Plat thereof as recorded in Plat Book 1, Page 31, of
the Public Records of Broward County, Florida."
RESPONSE: Upon reasonable inquiry, Defendant can neither admit or deny;
therefore denied.
3
DATED June 15, 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
Attorneys for GG RE
Hollywood Beach 613 LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June 15, 2023, I filed the foregoing document
electronically
with the Clerk of the Court using Florida Court's E-Filing Portal 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
4
Preview
Filing# 175391271 E-Filed 06/15/2023 11:29:20 AM INTHE CIRCUIT COURT OF THE 17 ,TH 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 ANSWERS TO SECOND REQUEST FOR ADMISSIONS FROM PLAINTIFF Defendant, GG RE HOLLYWOOD BEACH 613 LLC., by and through undersigned counsel and pursuant to Rule 1.370 ofthe Florida Rules of Civil Procedure, responds to Plaintiff, JOY FURER'S, Second Request for Admissions Dated May 16, 2023, as follows: 1. On April 29, 2019, GG RE Hollywood Beach 613 LLC was grantedthe Warranty Deed .. attached hereto as Exhibit "A' for the property located at 2012 North Surf Road, Hollywood, Florida 33019, e with the legaldescription: "Lots 1 through 5, 21 and 22, Block 9 of HOLLYWOOD BEACH FIRST ADDITION, accordingto the Plat thereof as recorded in Plat Book 1, Page 31, ofthe Public Records of Broward County, Florida." RESPONSE: Admitted. 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/15/2023 11:29:20 AM.**** 2. On January 5, 2021, GG RE Hollywood Beach 613 LLC was the owner of the property located at 2012 North Surf Road, Hollywood, Florida 33019, o which has the legal description: "Lots 1 through 5, 21 and 22, Block 9 of HOLLYWOOD BEACH FIRST ADDITION, according to the Plat thereof as recorded in Plat Book 1, Page 31, of the Public Records of Broward County, .. Florida.' RESPONSE: Admitted. 3. The document attached as Exhibit "A" is admissible in evidence at the trial of this matter. RESPONSE: Objection as this request goes beyond the permissiblescope of a Request for Admission and calls for a legal conclusion. 4. The website, bcpa.net,associated with Marty Kiar, elected Broward County, Florida Property Appraiser,is a widely accepted web service for determining property boundaries for propertieslocated within Broward County, Florida,such as the subjectproperty. RESPONSE: Denied. The website has the following disclaimer: " IMPORTANT 1 DISCLAIMER: This map is maintained for tax roll purposes only and may not be appropriate for other uses. The Broward County Property Appraiser's Office does not guarantee or make any representation regarding the information contained herein. This map is not a substitute for a title search or land survey. This map does not impact the interests of any person or properties,including any present or future ,, right or use of real property. Reliance upon this map is at the user's risk. 5. The document attached as Exhibit "B" is an authentic image from bcpa.net. RESPONSE: Objection as "- authentic" is vague and ambiguous. Moreover, the website has the following disclaimer: "IMPORTANT DISCLAIMER: This map is 2 maintained for tax roll purposes only and may not be appropriate for other uses. The Broward County Property Appraiser's Office does not guarantee or make any representation regarding the information contained herein. This map is not a substitute for a title search or land survey. This map does not impact the interests of any person or properties,including any present or future right or use of real property. map is at the user's risk. ,, Reliance upon this 6. The areas within the red perimetersdepictedin the document attached as Exhibit "B" are an accurate representationofthe parameters ofthe subjectproperty located at 2012 North Surf Road, Hollywood, Florida 33019, as was effective on or about the date ofthe subject incident. RESPONSE: Admitted. 7. The document attached as Exhibit "B" is admissible in evidence at the trial of this matter. RESPONSE: Objection as this request goes beyond the permissible scope of a Request for Admission and calls for a legal conclusion. 8. All of the area wherein Plaintiff allegesthe incident occurred, as described in Plaintiff's Complaint, is within the parameters of the property located at 2012 North Surf Road, Hollywood, Florida,33019, with the legaldescription: "Lots 1 through 5, 21 and 22, Block 9 of HOLLYWOOD BEACH FIRST ADDITION, accordingto the Plat thereof as recorded in Plat Book 1, Page 31, of the Public Records of Broward County, Florida." RESPONSE: Upon reasonable inquiry, Defendant can neither admit or deny; therefore denied. 3 DATED June 15, 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 Attorneys for GG RE Hollywood Beach 613 LLC CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 15, 2023, I filed the foregoing document electronically with the Clerk of the Court using Florida Court's E-Filing Portal 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 4