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# 152770232 E-Filed 07/06/2022 12:31:43 PM
IN THE CIRCUITCOURT OF THE 17
7TH
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 CO-DEFENDANT
RELAXPRO, LLC'S REQUEST FOR ADMISSIONS
Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through its undersigned
counsel and pursuant to Florida Rule of Civil Procedure 1.350, hereby submits its Responses to
Co-Defendant Relaxpro LLC's Request for Admissions as follows:
1. GG RE Hollywood Beach 613 LLC had a non-delegable duty to take such
precautionsas were reasonably necessary to protect its invitees from reasonably foreseeable
criminal attacks.
RESPONSE: Objection as this request improperly calls for a legal conclusion.
2. GG RE Hollywood Beach 613 LLC had the final authorityon matters that would
increase costs to be paid by GG RE Hollywood Beach 613 LLC such as the hiringof on-site
securityor off-dutypolice officers.
RESPONSE: Admitted.
3 GG RE Hollywood Beach 613 LLC never asked Relaxpro, LLC to hire on-site
securityor off-dutypoliceofficers to provide securityto the subjectpremises.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/06/2022 12:31:43 PM.****
RESPONSE: Admitted.
4. GG RE Hollywood Beach 613 LLC had previouslydenied Relaxpro,LLC's request
to make improvements on or around the subjectpremises.
RESPONSE: Denied.
DATED this 6?th day of July,2022.
ANDERSONGLENN LLP
/s/ Amanda N. Rumker
John J. Glenn, Esquire
Florida Bar No.. 957860
jglenn@asglaw.com
Amanda N. Rumker, Esquire
Florida Bar No.. 125580
arumker@asglaw.com
2650 North MilitaryTrail,Suite 430
Boca Raton, Florida 33341
Tel.: (561) 893-9192
Fax: (561) 893-9194
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 61-th day o f July,2022, I electronically
filed the foregoing
document with the Clerk of the Court using Florida Court's E-FilingPortal and certify
that all
counsel of record have been served via transmission of Notice of Electronic Filinggeneratedby
Florida Court E-FilingPortal or in some other authorized manner for those counsel or partieswho
Notices of Electronic Filing.
are not authorized to receive electronically
/s/ Amanda N. Rumker
Amanda N. Rumker, Esquire
Document Filed Date
July 06, 2022
Case Filing Date
August 31, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing# 152770232 E-Filed 07/06/2022 12:31:43 PM IN THE CIRCUITCOURT OF THE 17 7TH 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 CO-DEFENDANT RELAXPRO, LLC'S REQUEST FOR ADMISSIONS Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through its undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.350, hereby submits its Responses to Co-Defendant Relaxpro LLC's Request for Admissions as follows: 1. GG RE Hollywood Beach 613 LLC had a non-delegable duty to take such precautionsas were reasonably necessary to protect its invitees from reasonably foreseeable criminal attacks. RESPONSE: Objection as this request improperly calls for a legal conclusion. 2. GG RE Hollywood Beach 613 LLC had the final authorityon matters that would increase costs to be paid by GG RE Hollywood Beach 613 LLC such as the hiringof on-site securityor off-dutypolice officers. RESPONSE: Admitted. 3 GG RE Hollywood Beach 613 LLC never asked Relaxpro, LLC to hire on-site securityor off-dutypoliceofficers to provide securityto the subjectpremises. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/06/2022 12:31:43 PM.**** RESPONSE: Admitted. 4. GG RE Hollywood Beach 613 LLC had previouslydenied Relaxpro,LLC's request to make improvements on or around the subjectpremises. RESPONSE: Denied. DATED this 6?th day of July,2022. ANDERSONGLENN LLP /s/ Amanda N. Rumker John J. Glenn, Esquire Florida Bar No.. 957860 jglenn@asglaw.com Amanda N. Rumker, Esquire Florida Bar No.. 125580 arumker@asglaw.com 2650 North MilitaryTrail,Suite 430 Boca Raton, Florida 33341 Tel.: (561) 893-9192 Fax: (561) 893-9194 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 61-th day o f July,2022, I electronically filed the foregoing document with the Clerk of the Court using Florida Court's E-FilingPortal and certify that all counsel of record have been served via transmission of Notice of Electronic Filinggeneratedby Florida Court E-FilingPortal or in some other authorized manner for those counsel or partieswho Notices of Electronic Filing. are not authorized to receive electronically /s/ Amanda N. Rumker Amanda N. Rumker, Esquire