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.
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Filing# 150290609 E-Filed 05/25/2022 01:40:32 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
REQUEST FOR ADMISSIONS TO CO-DEFENDANT,
GG RE HOLLYWOOD BEACH 613, LLC
Defendant, RELAXPRO, LLC, by and through the undersigned attorney and pursuant to
Fla.R.Civ.P. 1.370, requests Defendant, GG RE HOLLYWOOD BEACH 613, LLC, to admit or
deny the following:
1. GG RE HOLLYWOOD BEACH LLC had
a non-delegableduty to take such
613,
precautionsas were reasonablynecessary to protect its invitees from reasonablyforeseeable criminal
attacks.
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-dutypoliceofficers.
3 GG RE HOLLYWOOD BEACH 613, LLC never asked RELAXPRO, LLC to hire
on-site securityor off-dutypoliceofficers to provide securityto the subjectpremises.
4. GG RE HOLLYWOOD BEACH 613, LLC had previouslydenied RELAXPRO,
LLC's requests to make improvements on or around the subjectpremises.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a copy ofthe foregoingwas furnished by email on May 25,
2022 to: Zachary Bodenheimer, Esq, Flanagan & Bodenheimer Injuryand Wrongful Death Law
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/25/2022 01:40:32 PM.****
Firm, 2525 Ponce de Leon Blvd., Suite 650, Coral Gables, FL 33145
ZDB@florida-justice.com;
.
and John J. Glenn, Esq., AndersonGlenn LLP, 2650 N. Military
mtfassistant@florida-justice.com
Trail, Suite 430, Boca Raton, FL 33431 jglenn@asglaw.com; arumker@asglaw.com;
kmoss@asglaw.com.
Respectfullysubmitted,
MITRANI, RYNOR, ADAMSKY &
TOLAND, P.A.
1200 Weston Road
Penthouse
Weston, Florida 33326
(954) 335-1010 Telephone
(954) 335-1017 Facsimile
BY:
ERIC C. SAGE
Florida Bar Number: 928577
esage@mitrani.com
ALICIA M. CORBO
Florida Bar Number: 1025354
acorbo@mitrani.com
AttorneysforDefendant,Relaxpro,
LLC
service@mitrani.com
2
Document Filed Date
May 25, 2022
Case Filing Date
August 31, 2021
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Filing# 150290609 E-Filed 05/25/2022 01:40:32 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 REQUEST FOR ADMISSIONS TO CO-DEFENDANT, GG RE HOLLYWOOD BEACH 613, LLC Defendant, RELAXPRO, LLC, by and through the undersigned attorney and pursuant to Fla.R.Civ.P. 1.370, requests Defendant, GG RE HOLLYWOOD BEACH 613, LLC, to admit or deny the following: 1. GG RE HOLLYWOOD BEACH LLC had a non-delegableduty to take such 613, precautionsas were reasonablynecessary to protect its invitees from reasonablyforeseeable criminal attacks. 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-dutypoliceofficers. 3 GG RE HOLLYWOOD BEACH 613, LLC never asked RELAXPRO, LLC to hire on-site securityor off-dutypoliceofficers to provide securityto the subjectpremises. 4. GG RE HOLLYWOOD BEACH 613, LLC had previouslydenied RELAXPRO, LLC's requests to make improvements on or around the subjectpremises. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a copy ofthe foregoingwas furnished by email on May 25, 2022 to: Zachary Bodenheimer, Esq, Flanagan & Bodenheimer Injuryand Wrongful Death Law 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/25/2022 01:40:32 PM.**** Firm, 2525 Ponce de Leon Blvd., Suite 650, Coral Gables, FL 33145 ZDB@florida-justice.com; . and John J. Glenn, Esq., AndersonGlenn LLP, 2650 N. Military mtfassistant@florida-justice.com Trail, Suite 430, Boca Raton, FL 33431 jglenn@asglaw.com; arumker@asglaw.com; kmoss@asglaw.com. Respectfullysubmitted, MITRANI, RYNOR, ADAMSKY & TOLAND, P.A. 1200 Weston Road Penthouse Weston, Florida 33326 (954) 335-1010 Telephone (954) 335-1017 Facsimile BY: ERIC C. SAGE Florida Bar Number: 928577 esage@mitrani.com ALICIA M. CORBO Florida Bar Number: 1025354 acorbo@mitrani.com AttorneysforDefendant,Relaxpro, LLC service@mitrani.com 2