On February 06, 2019 a
Party Notice
was filed
involving a dispute between
Flicker Construction Inc.,
Hughes, John, Iii,
and
Flicker, Roman,
Mid-Continent Casualty Company,
for Contract & Indebtedness
in the District Court of Miami-Dade County.
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Filing # 133866388 E-Filed 09/01/2021 03:09:47 PM
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
CIVIL DIVISION
JOHN HUGHES, III, as receiver of Flicker
Construction, Inc., an inactive Florida
corporation, CASE NO. 2019-CA-003916
Plaintiff,
vs.
ROMAN FLICKER and MID-CONTINENT
CASUALTY COMPANY,
Defendants.
/
MID-CONTINENT CASUALTY COMPANY'S EXPERT DISCLOSURE
Pursuant to this Court's Order, Mid-Continent Casualty Company ("MCC") submits the
following expert witness expected to testify at trial:
1. Robert Jose Rodriguez, Esq.
MKRS Law, PL
4000 Ponce de Leon Boulevard, Suite 470
Coral Gables, Florida 33146
Mr. Rodriguez specializes in the area of workers compensation law, and he is expected to
proffer testimony regarding Florida’s workers compensation statute and its application to general
contractors in the construction industry. Mr. Rodriguez’s testimony will support Mid-Continent
Casualty Company’s position that Flicker Construction is the general contractor that owed
workers compensation benefits to Manuel Perea.
4821-2906-0089.1
CASE NO. 2019-CA-003916
CERTIFICATE OF SERVICE
I certify that on September 1, 2021, the foregoing was filed via the Florida Courts eFiling
Portal which generates a copy to all counsel of record, including: Brandon G. Cathey, Esq,
and Brent G. Steinberg, Esq., Swope Rodante, P.A., 1234 East 5th Avenue, Tampa, Florida
33605, at team2eservice@swopelaw.com; eservice@swopelaw.com.
Respectfully submitted,
s/ Edward T. Sylvester
Edward T. Sylvester
Florida Bar No. 0051612
110 SE 6th Street, Suite 2600
Fort Lauderdale, Florida 33301
Telephone: 954-728-1280
Facsimile: 954-728-1282
Edward.Sylvester@lewisbrisbois.com
Counsel for Mid-Continent Cas. Co.
4821-2906-0089.1
Document Filed Date
September 01, 2021
Case Filing Date
February 06, 2019
Category
Contract & Indebtedness
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Filing # 133866388 E-Filed 09/01/2021 03:09:47 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION JOHN HUGHES, III, as receiver of Flicker Construction, Inc., an inactive Florida corporation, CASE NO. 2019-CA-003916 Plaintiff, vs. ROMAN FLICKER and MID-CONTINENT CASUALTY COMPANY, Defendants. / MID-CONTINENT CASUALTY COMPANY'S EXPERT DISCLOSURE Pursuant to this Court's Order, Mid-Continent Casualty Company ("MCC") submits the following expert witness expected to testify at trial: 1. Robert Jose Rodriguez, Esq. MKRS Law, PL 4000 Ponce de Leon Boulevard, Suite 470 Coral Gables, Florida 33146 Mr. Rodriguez specializes in the area of workers compensation law, and he is expected to proffer testimony regarding Florida’s workers compensation statute and its application to general contractors in the construction industry. Mr. Rodriguez’s testimony will support Mid-Continent Casualty Company’s position that Flicker Construction is the general contractor that owed workers compensation benefits to Manuel Perea. 4821-2906-0089.1 CASE NO. 2019-CA-003916 CERTIFICATE OF SERVICE I certify that on September 1, 2021, the foregoing was filed via the Florida Courts eFiling Portal which generates a copy to all counsel of record, including: Brandon G. Cathey, Esq, and Brent G. Steinberg, Esq., Swope Rodante, P.A., 1234 East 5th Avenue, Tampa, Florida 33605, at team2eservice@swopelaw.com; eservice@swopelaw.com. Respectfully submitted, s/ Edward T. Sylvester Edward T. Sylvester Florida Bar No. 0051612 110 SE 6th Street, Suite 2600 Fort Lauderdale, Florida 33301 Telephone: 954-728-1280 Facsimile: 954-728-1282 Edward.Sylvester@lewisbrisbois.com Counsel for Mid-Continent Cas. Co. 4821-2906-0089.1