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.
Preview
Filing # 130182469 E-Filed 07/07/2021 01:26:10 PM
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO.: 2019-CA-003916
JOHN HUGHES, III, as receiver of Flicker
Construction, Inc., an inactive Florida
corporation,
Plaintiff,
v.
ROMAN FLICKER and MID-CONTINENT
CASUALTY COMPANY,
Defendant,
___________________________________/
MID-CONTINENT CASUALTY COMPANY’S SECOND NOTICE OF
UNAVAILABILITY
Comes now Defendant, Mid-Continent Casualty Company (“MCC”), and hereby gives
notice to this Court of MCC’s unavailability for the second week of the trial term. Calendar call
was held on June 30, 2021, at which time the parties expressed their availability for the second and
third week of the trial term. Prior to the Calendar Call, the undersigned counsel gave notice of his
pending departure from Hinshaw & Culbertson, LLP to MCC, Hinshaw & Culbertson, LLP and
to counsel for Plaintiff. Because MCC had not yet decided as to the transfer of the file before
Calendar Call, the undersigned believed he was precluded from informing the Court. Earlier today,
undersigned counsel filed the stipulation of substitution of counsel with MCC’s signed consent
and a proposed order. Undersigned counsel does not want to seek a continuance but is unavailable
the second week of the July trial term due to the unavailability of MCC’s co-counsel, Keven
Vannatta—due to a prepaid vacation out of the country during the second week of the trial term.
4819-5951-1277.1
Moreover, as of this notice, the file has not yet been transferred from Hinshaw to Lewis Brisbois.
MCC will be prejudice if the trial is scheduled during the second week of the trial term.
Dated: July 7, 2021
By: /s/ Edward T. Sylvester
Edward T. Sylvester
Florida Bar No.: 51612
Edward.Sylvester@lewisbrisbois.com
Kevin Vannatta
Florida Bar No.: 872946
Kevin.Vannatta@lewisbrisbois.com
LEWIS BRISBOIS BISGAARD & SMITH
LLP
110 S.E. 6th Street, Suite 2600
Fort Lauderdale, Florida 33301
Tel.: 954-728-1280
Incoming Counsel for Mid-Continent
Casualty Company
CERTIFICATE OF SERVICE
I certify that on July 7, 2021, a true and correct copy of the foregoing was filed with the
Clerk of Court using the Florida Court’s E-Filing Portal and served by electronic mail using the
Florida Court’s E-Filing Portal upon all counsel of record authorized to receive service through
the Florida Court’s E-Filing Portal.
By: /s/ Edward T. Sylvester
Edward T. Sylvester
SERVICE LIST
Brent Steinberg
Brandon Cathey
Matthew Tyson Smith
Florida Bar No. 51580
Swope Rodante P.A.
1234 E 5th Ave
Tampa, FL 33605-4904
Telephone: 813-273-0017
Facsimile: 813-223-3678
E-mail: matthews@swopelaw.com; brents@swopelaw.com; brandonc@swopelaw.com
Team2eservice@swopelaw.com; eservice@swopelaw.com;
Counsels for Plaintiff
Document Filed Date
July 07, 2021
Case Filing Date
February 06, 2019
Category
Contract & Indebtedness
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Filing # 130182469 E-Filed 07/07/2021 01:26:10 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 2019-CA-003916 JOHN HUGHES, III, as receiver of Flicker Construction, Inc., an inactive Florida corporation, Plaintiff, v. ROMAN FLICKER and MID-CONTINENT CASUALTY COMPANY, Defendant, ___________________________________/ MID-CONTINENT CASUALTY COMPANY’S SECOND NOTICE OF UNAVAILABILITY Comes now Defendant, Mid-Continent Casualty Company (“MCC”), and hereby gives notice to this Court of MCC’s unavailability for the second week of the trial term. Calendar call was held on June 30, 2021, at which time the parties expressed their availability for the second and third week of the trial term. Prior to the Calendar Call, the undersigned counsel gave notice of his pending departure from Hinshaw & Culbertson, LLP to MCC, Hinshaw & Culbertson, LLP and to counsel for Plaintiff. Because MCC had not yet decided as to the transfer of the file before Calendar Call, the undersigned believed he was precluded from informing the Court. Earlier today, undersigned counsel filed the stipulation of substitution of counsel with MCC’s signed consent and a proposed order. Undersigned counsel does not want to seek a continuance but is unavailable the second week of the July trial term due to the unavailability of MCC’s co-counsel, Keven Vannatta—due to a prepaid vacation out of the country during the second week of the trial term. 4819-5951-1277.1 Moreover, as of this notice, the file has not yet been transferred from Hinshaw to Lewis Brisbois. MCC will be prejudice if the trial is scheduled during the second week of the trial term. Dated: July 7, 2021 By: /s/ Edward T. Sylvester Edward T. Sylvester Florida Bar No.: 51612 Edward.Sylvester@lewisbrisbois.com Kevin Vannatta Florida Bar No.: 872946 Kevin.Vannatta@lewisbrisbois.com LEWIS BRISBOIS BISGAARD & SMITH LLP 110 S.E. 6th Street, Suite 2600 Fort Lauderdale, Florida 33301 Tel.: 954-728-1280 Incoming Counsel for Mid-Continent Casualty Company CERTIFICATE OF SERVICE I certify that on July 7, 2021, a true and correct copy of the foregoing was filed with the Clerk of Court using the Florida Court’s E-Filing Portal and served by electronic mail using the Florida Court’s E-Filing Portal upon all counsel of record authorized to receive service through the Florida Court’s E-Filing Portal. By: /s/ Edward T. Sylvester Edward T. Sylvester SERVICE LIST Brent Steinberg Brandon Cathey Matthew Tyson Smith Florida Bar No. 51580 Swope Rodante P.A. 1234 E 5th Ave Tampa, FL 33605-4904 Telephone: 813-273-0017 Facsimile: 813-223-3678 E-mail: matthews@swopelaw.com; brents@swopelaw.com; brandonc@swopelaw.com Team2eservice@swopelaw.com; eservice@swopelaw.com; Counsels for Plaintiff