On February 06, 2019 a
Motion,Ex Parte
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 # 124507940 E-Filed 04/07/2021 03:47:41 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 CASE NO. 2019-CA-003916 CA 01 (27)
corporation,
Plaintiff,
vs.
ROMAN FLICKER and MID-CONTINENT
CASUALTY COMPANY,
Defendants.
/
DEFENDANT MID-CONTINENT CASUALTY COMPANY’S MOTION FOR
ENLARGEMENT OF TIME TO FILE WITNESS LIST
Mid-Continent Casualty Company (“MCC”), by and through its undersigned counsel,
hereby files this Motion for Enlargement of Time to File Witness List (“Motion”), and in support
thereof, states as follows:
1. MCC’s Witness List is due April 7, 2021.
2. MCC respectfully request an extension of time, up through and including
Monday, April 19, 2021, in which to file its Witness List.
3. Counsel for MCC is still reviewing the file, subpoenas and deposition transcripts.
4. MCC’s counsel contacted Plaintiff’s counsel via email regarding the requested
enlargement of time and counsel for the Plaintiff, Philip Stanwick, Esquire, has confirmed he has
no objection to the requested enlargement of time.
5. The additional time is not sought for the purpose of unnecessary delay and will
not prejudice any party to this litigation.
0979020\307891846.v1
CASE NO. 2019-CA-003916 CA 01 (27)
WHEREFORE, Mid-Continent Casualty Company respectfully requests that this
Honorable Court grant it’s Motion for Enlargement of Time to File Witness List granting MCC
an extension of time up through and including Monday, April 19, 2021 file it’s Witness List.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 7, 2021, a true and correct copy of the foregoing has
been filed via the E-Filing System and served on all counsel of record.
HINSHAW & CULBERTSON LLP
/s Edward T. Sylvester
Edward T. Sylvester
Florida Bar No. 51612
esylvester@hinshawlaw.com
lleon@hinshawlaw.com
2525 Ponce De Leon Boulevard, 4th Floor
Coral Gables, Florida 33134
(T) 305-358-7747; (F) 305-577-1063
Counsel for MCC
Page 2 of 2
0979020\307891846.v1
Document Filed Date
April 07, 2021
Case Filing Date
February 06, 2019
Category
Contract & Indebtedness
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Filing # 124507940 E-Filed 04/07/2021 03:47:41 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 CASE NO. 2019-CA-003916 CA 01 (27) corporation, Plaintiff, vs. ROMAN FLICKER and MID-CONTINENT CASUALTY COMPANY, Defendants. / DEFENDANT MID-CONTINENT CASUALTY COMPANY’S MOTION FOR ENLARGEMENT OF TIME TO FILE WITNESS LIST Mid-Continent Casualty Company (“MCC”), by and through its undersigned counsel, hereby files this Motion for Enlargement of Time to File Witness List (“Motion”), and in support thereof, states as follows: 1. MCC’s Witness List is due April 7, 2021. 2. MCC respectfully request an extension of time, up through and including Monday, April 19, 2021, in which to file its Witness List. 3. Counsel for MCC is still reviewing the file, subpoenas and deposition transcripts. 4. MCC’s counsel contacted Plaintiff’s counsel via email regarding the requested enlargement of time and counsel for the Plaintiff, Philip Stanwick, Esquire, has confirmed he has no objection to the requested enlargement of time. 5. The additional time is not sought for the purpose of unnecessary delay and will not prejudice any party to this litigation. 0979020\307891846.v1 CASE NO. 2019-CA-003916 CA 01 (27) WHEREFORE, Mid-Continent Casualty Company respectfully requests that this Honorable Court grant it’s Motion for Enlargement of Time to File Witness List granting MCC an extension of time up through and including Monday, April 19, 2021 file it’s Witness List. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 7, 2021, a true and correct copy of the foregoing has been filed via the E-Filing System and served on all counsel of record. HINSHAW & CULBERTSON LLP /s Edward T. Sylvester Edward T. Sylvester Florida Bar No. 51612 esylvester@hinshawlaw.com lleon@hinshawlaw.com 2525 Ponce De Leon Boulevard, 4th Floor Coral Gables, Florida 33134 (T) 305-358-7747; (F) 305-577-1063 Counsel for MCC Page 2 of 2 0979020\307891846.v1