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Filing# 167781521 E-Filed 03/01/2023 10:37:31 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, NOTICE OF SERVING
FIRST SET OF EXPERT INTERROGATORIES
Defendant, GG RE HOLLYWOOD BEACH 613 LLC., by and throughthe undersigned
counsel hereby gives notice of serving its First Set of Expert Interrogatories
upon the Plaintiff,
JOY FURER, pursuant to Rule 1.340 ofthe Florida Rules of Civil Procedure.
DATED March 1, 2023
ANDERSONGLENN LLP
/s/.John .J. Glenn
John J. Glenn, Esquire
Florida Bar Number: 957860
glenn@asglaw.com
Amanda N. Rumker, Esquire
Florida Bar No.: 125580
arumker@asglaw.com
2650 North MilitaryTrail,Suite 430
Boca Raton, Florida 33431
Telephone:(561) 893-9192
Facsimile: (561) 893-9194
CounselMDefendant
GG RE HOLLYWOOD BEACH 613 LLC
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/01/2023 10:37:30 AM.****
CASE NO.: CACE-21-016578
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 1, 2023, I filed the foregoingdocument
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
2
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, FIRST REQUEST FOR
EXPERT WITNESS INTERROGATORIES TO PLAINTIFF
Defendant, GG RE HOLLYWOOD BEACH 613 LLC., by and through undersigned
JOY
counsel hereby requests Plaintiff, FURER, pursuant to Rule 1.340 of the Florida Rules of
Civil Procedure, to produce the following items to counsel for Plaintiff,
within thirty(30) days
from the date herein:
1. With regardto each expert, you expect to call as a witness at trial,
pleasestate the
following:
a. Name, of expert(s).
address and specialty
b. The subjectmatter about which the expert is expected to testify.
c. The substance of the facts and opinion(s)which the expert is expected to express
in testifying.
d. A summary of the basis and grounds for each opinion to which the expert is
expected to testify.
CASE NO.: CACE-21-016578
e. The scope of employment for each retained expert in the above-captionedcase
and compensation for such service.
f. experience,includingthe percentage ofwork
The expert'sgenerallitigation
and defendants.
performed for plaintiffs
g. A list of all publicationswhich each expert identified above has authored, co-
authored,and the name of the publicationin which the article has appeared,or the
name of the publisherwho has publishedthe article,and enough information
about the publicationto enable Defendants to obtain it.
2. Have any ofyour experts in Interrogatory#1 rendered a report?If so, please state the
name of each expert who rendered a report, the date it the were rendered and
report(s)
identifyall persons in possession of said report(s) .
3. State the name and address of each person from whom you have obtained a statement,
oral,written,typed or otherwise, in this cause and also state:
a. The date of such statement.
b. Form of such statement.
c. Name and address of person who took the statement.
d. Subjectmatter of the statement.
e. typed or written,whether the person received a
If reported, copy of such
statement.
f. All persons in possessionof said statement(s).
DATED March 1, 2023
2
CASE NO.: CACE-21-016578
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 March 1,2023 ,
I filed the foregoingdocument
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
3
Preview
Filing# 167781521 E-Filed 03/01/2023 10:37:31 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, NOTICE OF SERVING FIRST SET OF EXPERT INTERROGATORIES Defendant, GG RE HOLLYWOOD BEACH 613 LLC., by and throughthe undersigned counsel hereby gives notice of serving its First Set of Expert Interrogatories upon the Plaintiff, JOY FURER, pursuant to Rule 1.340 ofthe Florida Rules of Civil Procedure. DATED March 1, 2023 ANDERSONGLENN LLP /s/.John .J. Glenn John J. Glenn, Esquire Florida Bar Number: 957860 glenn@asglaw.com Amanda N. Rumker, Esquire Florida Bar No.: 125580 arumker@asglaw.com 2650 North MilitaryTrail,Suite 430 Boca Raton, Florida 33431 Telephone:(561) 893-9192 Facsimile: (561) 893-9194 CounselMDefendant GG RE HOLLYWOOD BEACH 613 LLC 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/01/2023 10:37:30 AM.**** CASE NO.: CACE-21-016578 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 1, 2023, I filed the foregoingdocument 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 2 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, FIRST REQUEST FOR EXPERT WITNESS INTERROGATORIES TO PLAINTIFF Defendant, GG RE HOLLYWOOD BEACH 613 LLC., by and through undersigned JOY counsel hereby requests Plaintiff, FURER, pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, to produce the following items to counsel for Plaintiff, within thirty(30) days from the date herein: 1. With regardto each expert, you expect to call as a witness at trial, pleasestate the following: a. Name, of expert(s). address and specialty b. The subjectmatter about which the expert is expected to testify. c. The substance of the facts and opinion(s)which the expert is expected to express in testifying. d. A summary of the basis and grounds for each opinion to which the expert is expected to testify. CASE NO.: CACE-21-016578 e. The scope of employment for each retained expert in the above-captionedcase and compensation for such service. f. experience,includingthe percentage ofwork The expert'sgenerallitigation and defendants. performed for plaintiffs g. A list of all publicationswhich each expert identified above has authored, co- authored,and the name of the publicationin which the article has appeared,or the name of the publisherwho has publishedthe article,and enough information about the publicationto enable Defendants to obtain it. 2. Have any ofyour experts in Interrogatory#1 rendered a report?If so, please state the name of each expert who rendered a report, the date it the were rendered and report(s) identifyall persons in possession of said report(s) . 3. State the name and address of each person from whom you have obtained a statement, oral,written,typed or otherwise, in this cause and also state: a. The date of such statement. b. Form of such statement. c. Name and address of person who took the statement. d. Subjectmatter of the statement. e. typed or written,whether the person received a If reported, copy of such statement. f. All persons in possessionof said statement(s). DATED March 1, 2023 2 CASE NO.: CACE-21-016578 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 March 1,2023 , I filed the foregoingdocument 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 3