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Filing# 167781990 E-Filed 03/01/2023 10:40:36 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, FIRST REQUEST FOR
EXPERT WITNESS PRODUCTION TO PLAINTIFF
Defendant, GG RE HOLLYWOOD BEACH 613 LLC., by and through undersigned
JOY
counsel hereby requests Plaintiff, FURER, pursuant to Rule 1.350 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. For each expert that you have retained and expect to testify
at trial in this matter,
pleaseproduce your experts'entire file,cover to cover, related to this case, including
but not limited to any and all email communications, phone messages,
correspondence,and intake forms.
2. For each expert that you have retained and expect to testify
at trial in this matter,
pleaseproduce your experts'current Curriculum Vitae and/or resumes and fee
schedules.
3 For each expert that you have retained and expect to testify
at trial in this matter,
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/01/2023 10:40:36 AM.****
CASE NO.: CACE-21-016578
pleaseproduce your experts'complete billingfile in this case includingbut not
limited to, the chargesrendered, the statements rendered, the time spent on this case,
time sheets or records, and other relevant materials concerning the time and billings
in this case.
4. For each expert that you have retained and expect to testifyat trial in this matter,
pleaseproduce your experts'Elkins list.
5. For each expert that you have retained and expect to testify
at trial in this matter,
please produce any and all reports authored by your experts in this matter.
6. For each expert that you have retained and expect to testify
at trial in this matter,
pleaseproduce a list of all publicationsauthored or co-authored by your expert(s)
includingall paper, oral,or electronic sources.
7. For each expert that you have retained and expect to testify
at trial in this matter,
please produce any and all documents, exhibits,statements from witnesses, and
materials containingfacts upon which your expert has relied on or will relyon in
givinghis testimony in this case or which may be used to represent, illustrate or
explainhis/her testimony in this case. This includes all reports, studies,data
compilations,databases,photographs,and/or videos that the expert will or has relied
on to formulate opinionsin this matter.
8 For each expert that you have retained and expect to testifyat trial in this matter,
pleaseproduce any and all materials your experts received, reviewed, or prepared
relative to this matter, includingbut not limited to notes, letters,
memorandums,
statements, correspondence,photographs,videotapes,DVD's,
reports, depositions,
books, articles, films,tests, experiments,drawings or other materials
literature,
2
CASE NO.: CACE-21-016578
used by your experts or relied upon by your experts.
9- For each expert that you have retained and expect to testify
at trial in this matter,
please produce a copy of any and all tests and results of tests of any kind your experts
conducted or any conducted in this case.
10. For each expert that you have retained and expect to testifyat trial in this matter,
pleaseproduce any and all photographs,video tapes, diagrams,sketches,drawings,
and aerials your expert has reviewed and/or created regardingthe subjectmatter of
this litigation.
11. For each expert that you have retained and expect to testify
at trial in this matter,
pleaseproduce any and all manuals, guidelines,and/or
sources, publications,
other printed standards utilized by the expert in the formation of the expert's
opinionsincludingbut not limited to any Florida Statutes relied upon and/or
consulted and/or any other laws, rules or regulationswhich form the basis of the
expert'sopinionsin this case.
12. For each expert that you have retained and expect to testify
at trial in this matter,
please produce any documents for the preceding three (3)years which list the
work done on behalf ofplaintiffs
percentage ofthe expert'slitigation and defendants.
13. For each expert that you have retained and expect to testify
at trial in this matter,
please produce any documents for the preceding three (3)years which list the
time or work devoted to service as a litigation
portionof the expert'sprofessional
expert or consultant.
14. For each expert that you have retained and expect to testi]Y
at trial in this matter,
pleaseproduce any documents for the precedingthree (3)years which list the
3
CASE NO.: CACE-21-016578
percentage of income earned by the expert from expert litigation
related to services or
work.
DATED March 1, 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 March 1,2023 ,
I filed the foregoingdocument
electronically
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
4
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Filing# 167781990 E-Filed 03/01/2023 10:40:36 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, FIRST REQUEST FOR EXPERT WITNESS PRODUCTION TO PLAINTIFF Defendant, GG RE HOLLYWOOD BEACH 613 LLC., by and through undersigned JOY counsel hereby requests Plaintiff, FURER, pursuant to Rule 1.350 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. For each expert that you have retained and expect to testify at trial in this matter, pleaseproduce your experts'entire file,cover to cover, related to this case, including but not limited to any and all email communications, phone messages, correspondence,and intake forms. 2. For each expert that you have retained and expect to testify at trial in this matter, pleaseproduce your experts'current Curriculum Vitae and/or resumes and fee schedules. 3 For each expert that you have retained and expect to testify at trial in this matter, *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/01/2023 10:40:36 AM.**** CASE NO.: CACE-21-016578 pleaseproduce your experts'complete billingfile in this case includingbut not limited to, the chargesrendered, the statements rendered, the time spent on this case, time sheets or records, and other relevant materials concerning the time and billings in this case. 4. For each expert that you have retained and expect to testifyat trial in this matter, pleaseproduce your experts'Elkins list. 5. For each expert that you have retained and expect to testify at trial in this matter, please produce any and all reports authored by your experts in this matter. 6. For each expert that you have retained and expect to testify at trial in this matter, pleaseproduce a list of all publicationsauthored or co-authored by your expert(s) includingall paper, oral,or electronic sources. 7. For each expert that you have retained and expect to testify at trial in this matter, please produce any and all documents, exhibits,statements from witnesses, and materials containingfacts upon which your expert has relied on or will relyon in givinghis testimony in this case or which may be used to represent, illustrate or explainhis/her testimony in this case. This includes all reports, studies,data compilations,databases,photographs,and/or videos that the expert will or has relied on to formulate opinionsin this matter. 8 For each expert that you have retained and expect to testifyat trial in this matter, pleaseproduce any and all materials your experts received, reviewed, or prepared relative to this matter, includingbut not limited to notes, letters, memorandums, statements, correspondence,photographs,videotapes,DVD's, reports, depositions, books, articles, films,tests, experiments,drawings or other materials literature, 2 CASE NO.: CACE-21-016578 used by your experts or relied upon by your experts. 9- For each expert that you have retained and expect to testify at trial in this matter, please produce a copy of any and all tests and results of tests of any kind your experts conducted or any conducted in this case. 10. For each expert that you have retained and expect to testifyat trial in this matter, pleaseproduce any and all photographs,video tapes, diagrams,sketches,drawings, and aerials your expert has reviewed and/or created regardingthe subjectmatter of this litigation. 11. For each expert that you have retained and expect to testify at trial in this matter, pleaseproduce any and all manuals, guidelines,and/or sources, publications, other printed standards utilized by the expert in the formation of the expert's opinionsincludingbut not limited to any Florida Statutes relied upon and/or consulted and/or any other laws, rules or regulationswhich form the basis of the expert'sopinionsin this case. 12. For each expert that you have retained and expect to testify at trial in this matter, please produce any documents for the preceding three (3)years which list the work done on behalf ofplaintiffs percentage ofthe expert'slitigation and defendants. 13. For each expert that you have retained and expect to testify at trial in this matter, please produce any documents for the preceding three (3)years which list the time or work devoted to service as a litigation portionof the expert'sprofessional expert or consultant. 14. For each expert that you have retained and expect to testi]Y at trial in this matter, pleaseproduce any documents for the precedingthree (3)years which list the 3 CASE NO.: CACE-21-016578 percentage of income earned by the expert from expert litigation related to services or work. DATED March 1, 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 March 1,2023 , I filed the foregoingdocument electronically 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 4