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Filing # 139733169 E-Filed 12/05/2021 05:33:41 PM
IN THE CIRCUIT COURT OF THE 15™
JUDICIAL CIRCUIT, IN AD FOR
PALM BEACH COUNTY, FLORIDA
CASE NO.: 5-2021-CA-010108
MARION J. YOUNG BUTERA and
THOMAS BUTERA, her spouse
Plaintiff,
vs.
EDENS LIMITED PARTNERSHIP D/B/A
SUNSHINE SQUARE PLAZA and
THE BRIGHTVIEW LANDSCAPES, LLC
Defendants.
EDENS LIMITED PARTNERSHIP D/B/A
SUNSHINE SQUARE PLAZA,
Cross-Plaintiff,
vs.
THE BRIGHTVIEW LANDSCAPES, LLC,
Cross-Defendant
/
PLAINTIFF, MARION J. YOUNG BUTERA’S
RESPONSE TO INTE§ ROGATORIES
1 Marion J. Young-Butera
DOB August 16, 1944
I live with my husband Thomas at 1702 SW 14" Avenue, Boynton Beach, FL 33426
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/05/2021 05:33:41 PM ***10.
11.
12,
13.
14.
15.
16.
11/18-2/20
JB Cruises, 7460 Boynton Beach Blvd, Boynton Beach, FL 33437 $15/hour
see » Federal Hwy, Boca Raton, FL 33431 $18/hour
Marion J. Cooper
8/6/1944-7/29/63
Le
10038 Lexington Circle N, Boynton Beach, FL 33426 6/24/1992-7/20/2012
1105 Siesta Avenue, Boynton Beach, FL 33426 7/20/2012-8/4/2012
17025 W 14" Ave, Boynton Beach, FL 33426 8/4/2012 to present
I do not wear glasses, except to read, or hearing aids. South Florida Vision, Military Trail,
Boynton Beach, FL 8/4/20 as of 8/4/20
No
No, none
No, none
I was walking back to the car to get a credit card, I was following the others walking
through the pathway created by the shopping center. I tripped on a sprinkler head in the
path. I flew into the air and landed on the cement as | had tried to break my fall. I
immediately felt an intense pain.
In retrospect the shopping center should never have created a wide walkway through the
hedges. They left a sprinkler head in the pathway which created a danger to anyone
walking on that path. It was a matter of time before someone tripped and got seriously
injured. Unfortunately it was me.
No.
Broken femur and left shoulder replaced, cannot move left arm without pain.
Physical therapy
Yes, I lost my job
Some unemployment benefits
Bethesda Hospital ER
Martha Rodriguez MD17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
30.
My husband Thomas
Lucy Hadley, 8977 Midnight Pass Road, Sarasota, FL 34242
Unknown
My attomey and insurance company
No
Slip & Fall, BJ’s 8/9/2020, broken femur
Passenger in motor vehicle accident in friend’s car 1/20/10
No
None
Barry G. Hoffman, Esq., Attorney representing me in this matter.
I tripped over a sprinkler head which was extruding in the pathway created by the
shopping center.
Unknown, I don’t know how long this dangerous condition existed but the property
managers and landscapers should have known there was a pathway with an extruding
sprinkler head and corrected it.
Thad been on these premises before but parked from a different area so I went in a
different way,
A stranger used my cell phone to call my husband Thomas (TMobile 561-413-8931) to
tell him that I had been hurt in an accident. A stranger used his cell phone to call 911.OATH
Ido solemnly swear and affirm under the penalties of perjury that the foregoing Answers to
Interrogatories are true and correct to the best of my knowledge, information and belief.
Respectiily submitted,
LAW
9045
FICES OF BARRY G. HOFFMAN
‘ontana Blvd., Suite 106
Boca Haton, FL 33434
Telephone: (56{)\482-2000
/ ~~
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing pleading was sent via
email via the Florida Courts E-Filing Portal (pursuant to Rule 2.516, Florida Rules of Judicial
Administration and Administrative Order SC13.49, to Keith J. Lambdin, Esq., Erik J. Willman,
Esq., Agnant & Lambdin, LLC, 2 South University Drive, Suite 315, Fort Lauderdale, FL 33324;
David J. Majcak, Esq., Law Offices of Goldberg Segalla, LLP, 222 Lakeview Avenue, Suite 800,
West Palm Beach, FL 33401; and James W. Kehoe Ill, 3230 West Commercial Blvd., Fort
Lauderdale, FL 33309 on this -3, day of. (\SenAburr
Preview
Filing # 139733169 E-Filed 12/05/2021 05:33:41 PM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT, IN AD FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 5-2021-CA-010108 MARION J. YOUNG BUTERA and THOMAS BUTERA, her spouse Plaintiff, vs. EDENS LIMITED PARTNERSHIP D/B/A SUNSHINE SQUARE PLAZA and THE BRIGHTVIEW LANDSCAPES, LLC Defendants. EDENS LIMITED PARTNERSHIP D/B/A SUNSHINE SQUARE PLAZA, Cross-Plaintiff, vs. THE BRIGHTVIEW LANDSCAPES, LLC, Cross-Defendant / PLAINTIFF, MARION J. YOUNG BUTERA’S RESPONSE TO INTE§ ROGATORIES 1 Marion J. Young-Butera DOB August 16, 1944 I live with my husband Thomas at 1702 SW 14" Avenue, Boynton Beach, FL 33426 *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/05/2021 05:33:41 PM ***10. 11. 12, 13. 14. 15. 16. 11/18-2/20 JB Cruises, 7460 Boynton Beach Blvd, Boynton Beach, FL 33437 $15/hour see » Federal Hwy, Boca Raton, FL 33431 $18/hour Marion J. Cooper 8/6/1944-7/29/63 Le 10038 Lexington Circle N, Boynton Beach, FL 33426 6/24/1992-7/20/2012 1105 Siesta Avenue, Boynton Beach, FL 33426 7/20/2012-8/4/2012 17025 W 14" Ave, Boynton Beach, FL 33426 8/4/2012 to present I do not wear glasses, except to read, or hearing aids. South Florida Vision, Military Trail, Boynton Beach, FL 8/4/20 as of 8/4/20 No No, none No, none I was walking back to the car to get a credit card, I was following the others walking through the pathway created by the shopping center. I tripped on a sprinkler head in the path. I flew into the air and landed on the cement as | had tried to break my fall. I immediately felt an intense pain. In retrospect the shopping center should never have created a wide walkway through the hedges. They left a sprinkler head in the pathway which created a danger to anyone walking on that path. It was a matter of time before someone tripped and got seriously injured. Unfortunately it was me. No. Broken femur and left shoulder replaced, cannot move left arm without pain. Physical therapy Yes, I lost my job Some unemployment benefits Bethesda Hospital ER Martha Rodriguez MD17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 30. My husband Thomas Lucy Hadley, 8977 Midnight Pass Road, Sarasota, FL 34242 Unknown My attomey and insurance company No Slip & Fall, BJ’s 8/9/2020, broken femur Passenger in motor vehicle accident in friend’s car 1/20/10 No None Barry G. Hoffman, Esq., Attorney representing me in this matter. I tripped over a sprinkler head which was extruding in the pathway created by the shopping center. Unknown, I don’t know how long this dangerous condition existed but the property managers and landscapers should have known there was a pathway with an extruding sprinkler head and corrected it. Thad been on these premises before but parked from a different area so I went in a different way, A stranger used my cell phone to call my husband Thomas (TMobile 561-413-8931) to tell him that I had been hurt in an accident. A stranger used his cell phone to call 911.OATH Ido solemnly swear and affirm under the penalties of perjury that the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information and belief. Respectiily submitted, LAW 9045 FICES OF BARRY G. HOFFMAN ‘ontana Blvd., Suite 106 Boca Haton, FL 33434 Telephone: (56{)\482-2000 / ~~ CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing pleading was sent via email via the Florida Courts E-Filing Portal (pursuant to Rule 2.516, Florida Rules of Judicial Administration and Administrative Order SC13.49, to Keith J. Lambdin, Esq., Erik J. Willman, Esq., Agnant & Lambdin, LLC, 2 South University Drive, Suite 315, Fort Lauderdale, FL 33324; David J. Majcak, Esq., Law Offices of Goldberg Segalla, LLP, 222 Lakeview Avenue, Suite 800, West Palm Beach, FL 33401; and James W. Kehoe Ill, 3230 West Commercial Blvd., Fort Lauderdale, FL 33309 on this -3, day of. (\SenAburr