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Filing# 163964411 E-Filed 01/03/2023 12:32:03 PM
22022 IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
JOY FURER, CASE NO.: CACE-21-016578
Plaintiff,
VS.
GG RE HOLLYWOOD BEACH 613 LLC
and RELAXPRO LLC,
Defendants.
i
WITNESS LIST
Defendant, RELAXPRO LLC, by and through undersigned counsel and pursuant to this
Court's June 30,2022 Uniform Trial Order, hereby files its Fact Witness Disclosure as follows:
1. Joy Furer
c/o Plaintiff' s Counsel
Plaintiff is expected to testify she claims resulted from the
to the allegedincident,injuries
allegedincident and the allegationsin her Complaint.
2. Shahar Goldboim
c/oundersignedcounsel
Mr. Goldboim is expected to testify
regardingthe management of the Neptune Hotel, the
management agreement with GG RE Hollywood Beach 613 LLC and defenses to
Plaintiff' s Complaint.
3. Viktor Goldenberg
c/o Defendant's Counsel
regardinghis ownership of the Neptune Hotel, the
Mr. Goldenberg is expected to testify
management agreement with Relaxpro, LLC, and defenses to Plaintiff's Complaint.
4. Advanced Recovery Records Custodian
1501 Newkirk Avenue, Suite 585, Brooklyn, NY 11226
This records custodian expected to testifyregarding Plaintiff's medical records,
is
authenticityof said medical records, medical care, medical bills and/or treatment of
Plaintiff.
5. Alan Dayan, M.D. Records Custodian
J.
1715 Avenue T, Brooklyn, NY 11229
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/03/2023 12:32:02 PM.****
This records custodian isexpected to testifyregarding Plaintiff's medical records,
authenticityof said medical records, medical care, medical bills and/or treatment of
Plaintiff.
6. Arthur M. Lubitz, M.D. Records Custodian
315 West 57th Street,Suite 309, New York, NY 10019
This records custodian is expected to testifyregarding Plaintiff's medical records,
of
authenticity said medical records, medical care, medical bills and/or treatment of
Plaintiff.
7. Brooklyn Premier Orthopedics Records Custodian
1414 Newkirk Avenue, Brooklyn, NY 11226
This records custodian is expected to testifyregarding Plaintiff's medical records,
of
authenticity said medical records, medical care, medical bills and/or treatment of
Plaintiff.
8 Chelsea Skin and Laser Records Custodian
245 W. 19th Street,New York, NY, 10011
This records custodian isexpected to testifyregarding Plaintiff's medical records,
authenticityof said medical records, medical care, medical bills and/or treatment of
Plaintiff.
9- Hollywood Fire Rescue Records Custodian
Road, Fort Lauderdale, FL 33312
2741 Stirling
This records custodian is expected to testifyregarding Plaintiff's medical records,
authenticityof said medical records, medical care, medical bills and/or treatment of
Plaintiff.
10. Memorial Healthcare System Records Custodian
3501 Johnson Street,Hollywood, FL 33021
This records custodian is expected to testifyregarding Plaintiff's medical records,
authenticityof said medical records, medical care, medical bills and/or treatment of
Plaintiff.
11. North Queens SurgicalCenter Records Custodian
45-64 Francis Lewis Blvd., Suite 200, Bayside,NY 11361
This records custodian isexpected to testifyregarding Plaintiff's medical records,
authenticityof said medical records, medical care, medical bills and/or treatment of
Plaintiff.
12. Rogosin Institute Records Custodian
505 E. 70'U Street,New York, NY 10021
th
This records custodian isexpected to testifyregarding Plaintiff's medical records,
authenticityof said medical records, medical care, medical bills and/or treatment of
Plaintiff.
13. Stand-Up MRI of Bensonhurst Records Custodian
2671 86I Street,Brooklyn, NY 11223
th
This records custodian expected to testifyregarding Plaintiff's medical records,
is
authenticityof said medical records, medical care, medical bills and/or treatment of
Plaintiff.
14. Hollywood Police Department Records Custodian
3250 Hollywood Blvd., Hollywood, FL 33021
This records custodian is expected to testifyregarding Plaintiff's police report,
and
authenticity findingscontained therein.
15. G.L. Kastner
3250 Hollywood Blvd., Hollywood, FL 33021
This officer
is expected to testifyregarding Plaintiff's police report, authenticityand
findingscontained therein.
16. L. Kimble
3250 Hollywood Blvd., Hollywood, FL 33021
and
This officer is expected to testifyregardingPlaintiff's police report, authenticity
findingscontained therein.
17. N. Nembhard
3250 Hollywood Blvd., Hollywood, FL 33021
and
This officer is expected to testifyregardingPlaintiff's police report, authenticity
findingscontained therein.
18. C. Rivas
3250 Hollywood Blvd., Hollywood, FL 33021
and
This officer is expected to testifyregardingPlaintiff's police report, authenticity
findingscontained therein.
19. A. Zeidell
3250 Hollywood Blvd., Hollywood, FL 33021
This officer regarding Plaintiff's police report, authenticityand
is expected to testify
findingscontained therein.
20. K. Doyle
3250 Hollywood Blvd., Hollywood, FL 33021
This officer regarding Plaintiff's police report, authenticityand
is expected to testify
findingscontained therein.
21. All partiesto this lawsuit and any representative
thereof.
22. All witnesses listed in Plaintiff's Witness List.
23. All witnesses listed in Defendant, GG RE HOLLYWOOD BEACH 613 LLC's, witness
list.
24. Any and all records custodians.
25. All of Plaintiff's treating
physicians.
26. Any and all impeachment witnesses.
27. Any and all rebuttal witnesses.
28. All persons whose depositionshave been taken in this action.
29. Any and all witnesses identified duringdiscoverynot completed to date.
30. Any and all issued subpoenas in
persons/entities this action.
31. Any and all persons named in Answers to Interrogatories and/or in response to Request
for Production which have been served in this action or will be served priorto trial.
32. Defendant reserves the rightto call any and all witnesses listed by any of the other parties
to this lawsuit.
33. Defendant reserves the rightto supplement and/or amend this Witness List.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the within and foregoinghas
on January 3,2023 via the Court's approved electronic filingsystem,
been filed electronically
which will automaticallysend email notification of such filing
to all counsel of record.
MITRANI, RYNOR, ADAMSKY
& TOLAND, P.A.
1200 Weston Road
Penthouse
Weston, Florida 33326
(954) 335-1010 Telephone
(954) 335-1017 Facsimile
BY:
ALVPMGAA
ALICIA CORBO
Florida Bar Number: 1025354
acorbo@mitrani.com
ERIC C. SAGE
Florida Bar Number: 928577
esage@mitrani.com
Attorneys for Defendant,
RELAXPRO LLC
service@mitrani.com
Preview
Filing# 163964411 E-Filed 01/03/2023 12:32:03 PM 22022 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JOY FURER, CASE NO.: CACE-21-016578 Plaintiff, VS. GG RE HOLLYWOOD BEACH 613 LLC and RELAXPRO LLC, Defendants. i WITNESS LIST Defendant, RELAXPRO LLC, by and through undersigned counsel and pursuant to this Court's June 30,2022 Uniform Trial Order, hereby files its Fact Witness Disclosure as follows: 1. Joy Furer c/o Plaintiff' s Counsel Plaintiff is expected to testify she claims resulted from the to the allegedincident,injuries allegedincident and the allegationsin her Complaint. 2. Shahar Goldboim c/oundersignedcounsel Mr. Goldboim is expected to testify regardingthe management of the Neptune Hotel, the management agreement with GG RE Hollywood Beach 613 LLC and defenses to Plaintiff' s Complaint. 3. Viktor Goldenberg c/o Defendant's Counsel regardinghis ownership of the Neptune Hotel, the Mr. Goldenberg is expected to testify management agreement with Relaxpro, LLC, and defenses to Plaintiff's Complaint. 4. Advanced Recovery Records Custodian 1501 Newkirk Avenue, Suite 585, Brooklyn, NY 11226 This records custodian expected to testifyregarding Plaintiff's medical records, is authenticityof said medical records, medical care, medical bills and/or treatment of Plaintiff. 5. Alan Dayan, M.D. Records Custodian J. 1715 Avenue T, Brooklyn, NY 11229 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/03/2023 12:32:02 PM.**** This records custodian isexpected to testifyregarding Plaintiff's medical records, authenticityof said medical records, medical care, medical bills and/or treatment of Plaintiff. 6. Arthur M. Lubitz, M.D. Records Custodian 315 West 57th Street,Suite 309, New York, NY 10019 This records custodian is expected to testifyregarding Plaintiff's medical records, of authenticity said medical records, medical care, medical bills and/or treatment of Plaintiff. 7. Brooklyn Premier Orthopedics Records Custodian 1414 Newkirk Avenue, Brooklyn, NY 11226 This records custodian is expected to testifyregarding Plaintiff's medical records, of authenticity said medical records, medical care, medical bills and/or treatment of Plaintiff. 8 Chelsea Skin and Laser Records Custodian 245 W. 19th Street,New York, NY, 10011 This records custodian isexpected to testifyregarding Plaintiff's medical records, authenticityof said medical records, medical care, medical bills and/or treatment of Plaintiff. 9- Hollywood Fire Rescue Records Custodian Road, Fort Lauderdale, FL 33312 2741 Stirling This records custodian is expected to testifyregarding Plaintiff's medical records, authenticityof said medical records, medical care, medical bills and/or treatment of Plaintiff. 10. Memorial Healthcare System Records Custodian 3501 Johnson Street,Hollywood, FL 33021 This records custodian is expected to testifyregarding Plaintiff's medical records, authenticityof said medical records, medical care, medical bills and/or treatment of Plaintiff. 11. North Queens SurgicalCenter Records Custodian 45-64 Francis Lewis Blvd., Suite 200, Bayside,NY 11361 This records custodian isexpected to testifyregarding Plaintiff's medical records, authenticityof said medical records, medical care, medical bills and/or treatment of Plaintiff. 12. Rogosin Institute Records Custodian 505 E. 70'U Street,New York, NY 10021 th This records custodian isexpected to testifyregarding Plaintiff's medical records, authenticityof said medical records, medical care, medical bills and/or treatment of Plaintiff. 13. Stand-Up MRI of Bensonhurst Records Custodian 2671 86I Street,Brooklyn, NY 11223 th This records custodian expected to testifyregarding Plaintiff's medical records, is authenticityof said medical records, medical care, medical bills and/or treatment of Plaintiff. 14. Hollywood Police Department Records Custodian 3250 Hollywood Blvd., Hollywood, FL 33021 This records custodian is expected to testifyregarding Plaintiff's police report, and authenticity findingscontained therein. 15. G.L. Kastner 3250 Hollywood Blvd., Hollywood, FL 33021 This officer is expected to testifyregarding Plaintiff's police report, authenticityand findingscontained therein. 16. L. Kimble 3250 Hollywood Blvd., Hollywood, FL 33021 and This officer is expected to testifyregardingPlaintiff's police report, authenticity findingscontained therein. 17. N. Nembhard 3250 Hollywood Blvd., Hollywood, FL 33021 and This officer is expected to testifyregardingPlaintiff's police report, authenticity findingscontained therein. 18. C. Rivas 3250 Hollywood Blvd., Hollywood, FL 33021 and This officer is expected to testifyregardingPlaintiff's police report, authenticity findingscontained therein. 19. A. Zeidell 3250 Hollywood Blvd., Hollywood, FL 33021 This officer regarding Plaintiff's police report, authenticityand is expected to testify findingscontained therein. 20. K. Doyle 3250 Hollywood Blvd., Hollywood, FL 33021 This officer regarding Plaintiff's police report, authenticityand is expected to testify findingscontained therein. 21. All partiesto this lawsuit and any representative thereof. 22. All witnesses listed in Plaintiff's Witness List. 23. All witnesses listed in Defendant, GG RE HOLLYWOOD BEACH 613 LLC's, witness list. 24. Any and all records custodians. 25. All of Plaintiff's treating physicians. 26. Any and all impeachment witnesses. 27. Any and all rebuttal witnesses. 28. All persons whose depositionshave been taken in this action. 29. Any and all witnesses identified duringdiscoverynot completed to date. 30. Any and all issued subpoenas in persons/entities this action. 31. Any and all persons named in Answers to Interrogatories and/or in response to Request for Production which have been served in this action or will be served priorto trial. 32. Defendant reserves the rightto call any and all witnesses listed by any of the other parties to this lawsuit. 33. Defendant reserves the rightto supplement and/or amend this Witness List. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the within and foregoinghas on January 3,2023 via the Court's approved electronic filingsystem, been filed electronically which will automaticallysend email notification of such filing to all counsel of record. MITRANI, RYNOR, ADAMSKY & TOLAND, P.A. 1200 Weston Road Penthouse Weston, Florida 33326 (954) 335-1010 Telephone (954) 335-1017 Facsimile BY: ALVPMGAA ALICIA CORBO Florida Bar Number: 1025354 acorbo@mitrani.com ERIC C. SAGE Florida Bar Number: 928577 esage@mitrani.com Attorneys for Defendant, RELAXPRO LLC service@mitrani.com