On February 06, 2019 a
Request,Application
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 # 113513555 E-Filed 09/17/2020 11:03:14 AM
IN THE CIRCUIT COURT OF THE 11th
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
JOHN HUGHES, III, as Receiver of
FLICKER CONSTRUCTION, INC.,
Plaintiff,
CASE NO.: 2019-003916-CA-01
v.
ROMAN FLICKER and MID-CONTINENT
CASUALTY COMPANY,
Defendants.
_____________________________________/
PLAINTIFF’S REQUEST FOR COPIES
Plaintiff, JOHN HUGHES, III, by and through their undersigned counsel, hereby requests
a complete copy of any and all documents received by Defendant MID-CONTINENT
CASUALTY COMPANY in response to their Subpoena Duces Tecum Without Deposition served
upon Non-Party, City of Miami Building.
Plaintiff agrees to pay the reasonable cost of duplicating the materials produced in response
to Defendant’s subpoena duces tecum without deposition, not to exceed $50.00 per subpoena. If
the reasonable cost of duplicating the materials produced in response to the Defendant’s subpoena
will exceed $50.00, please contact Plaintiff’s counsel before providing the copies to discuss the
costs of production.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically
filed and furnished by e-mail to Edward T. Sylvester, esylvester@hinshawlaw.com,
lleon@hinshawlaw.com, and Alina Yaniz, ayaniz@hinshawlaw.com, Hinshaw & Culbertson
LLP, 2525 Ponce de Leon Blvd., 4th Floor, Coral Gables, FL 33134, on this 17th day of
September, 2020.
/s/ Daniel L. Greene
BRANDON G. CATHEY
Florida Bar No.: 941891
DANIEL L. GREENE
Florida Bar No.: 1003266
SWOPE, RODANTE P.A.
1234 E. 5th Ave., Tampa, Florida 33605
Tel: (813) 273-0017/ Fax: (813) 223-3678
Team2eservice@swopelaw.com
eservice@swopelaw.com
Attorneys for Plaintiff
Document Filed Date
September 17, 2020
Case Filing Date
February 06, 2019
Category
Contract & Indebtedness
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Filing # 113513555 E-Filed 09/17/2020 11:03:14 AM IN THE CIRCUIT COURT OF THE 11th JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA JOHN HUGHES, III, as Receiver of FLICKER CONSTRUCTION, INC., Plaintiff, CASE NO.: 2019-003916-CA-01 v. ROMAN FLICKER and MID-CONTINENT CASUALTY COMPANY, Defendants. _____________________________________/ PLAINTIFF’S REQUEST FOR COPIES Plaintiff, JOHN HUGHES, III, by and through their undersigned counsel, hereby requests a complete copy of any and all documents received by Defendant MID-CONTINENT CASUALTY COMPANY in response to their Subpoena Duces Tecum Without Deposition served upon Non-Party, City of Miami Building. Plaintiff agrees to pay the reasonable cost of duplicating the materials produced in response to Defendant’s subpoena duces tecum without deposition, not to exceed $50.00 per subpoena. If the reasonable cost of duplicating the materials produced in response to the Defendant’s subpoena will exceed $50.00, please contact Plaintiff’s counsel before providing the copies to discuss the costs of production. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically filed and furnished by e-mail to Edward T. Sylvester, esylvester@hinshawlaw.com, lleon@hinshawlaw.com, and Alina Yaniz, ayaniz@hinshawlaw.com, Hinshaw & Culbertson LLP, 2525 Ponce de Leon Blvd., 4th Floor, Coral Gables, FL 33134, on this 17th day of September, 2020. /s/ Daniel L. Greene BRANDON G. CATHEY Florida Bar No.: 941891 DANIEL L. GREENE Florida Bar No.: 1003266 SWOPE, RODANTE P.A. 1234 E. 5th Ave., Tampa, Florida 33605 Tel: (813) 273-0017/ Fax: (813) 223-3678 Team2eservice@swopelaw.com eservice@swopelaw.com Attorneys for Plaintiff