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  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview
  • VILLAS AT EMERALD LAKE HOMEOWNERS ASSOCIATION INC vs. ROYAL OAK HOMES LLC CONSTRUCTION DEFECT-OTHER NEGLIGENCE document preview 
						
                                
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                                Filing # 137580320 E-Filed 10/29/2021 04:57:55 PM



                                                                 IN THE CIRCUIT COURT OF THE 9™
                                                                 JUDICIAL  CIRCUIT  IN  AND  FOR
                                                                 OSCEOLA COUNTY, FLORIDA

                                                                 CASE NO.:   2020-CA-002942

         VILLAS   AT                 EMERALD            LAKE
         HOMEOWNERS                ASSOCIATION,       INC., a
         Florida not for profit corporation;

                   Plaintiff,

         Vv.

         ROYAL         OAK        HOMES,
                                     LLC, a Florida
         limited      liability    company,
                                        ADVANCED
         WRAPPING           AND          CONCRETE
         SOLUTIONS      OF CENTRAL        FLORIDA,
         INC., a Florida corporation; DON KING’S
         CONCRETE, INC., a Florida corporation;
         HUGH MACDONALD CONSTRUCTION,
         INC., a Florida corporation; IMPERIAL
         BUILDING      CORPORATION,        a Florida
         corporation; PREMIER PLASTERING OF
         CENTRAL FLORIDA, INC. N/K/A TGK
         STUCCO,          INC.,     a   Florida   corporation;
         WEATHERMASTER                   BUILDING
         PRODUCTS, INC., a Florida corporation;
         WEINTRAUB           INSPECTIONS           &
         FORENSICS, INC. N/K/A WEINTRAUB
         ENGINEERING AND INSPECTIONS, INC.,
         a Florida corporation; THE       DIMILLO
         GROUP, LLC, a Florida limited liability
         company;     WOLF’S     IRRIGATIONS       &
         LANDSCAPING, INC., a Florida corporation;
         SUMMERPARK HOMES, INC., a Florida
         corporation;   BROWN        + COMPANY
         ARCHITECTURE,         INC.,   a     Florida
         corporation,

                   Defendants.
CASE NO.:   2020-CA-002942


ROYAL OAK HOMES,                  LLC,       a   Florida
limited liability company;

        Crossclaim Plaintiff,




ADVANCED           WRAPPING           AND
CONCRETE SOLUTIONS OF CENTRAL
FLORIDA, INC., a Florida corporation; DON
KING’S      CONCRETE,    INC.,   a Florida
corporation;     HUGH       MACDONALD
CONSTRUCTION,      INC.,                 a       Florida
corporation; IMPERIAL,                   BUILDING
CORPORATION,    a Florida                corporation;
PREMIER        PLASTERING OF CENTRAL
FLORIDA,        INC. N/K/A TGK STUCCO,
INC.,         a        Florida     corporation;
WEATHERMASTER                      BUILDING
PRODUCTS, INC., a Florida corporation;
WEINTRAUB                INSPECTIONS          &
FORENSICS, INC. N/K/A WEINTRAUB
ENGINEERING AND INSPECTIONS, INC.,
a       Florida       corporation;    WOLF’S
IRRIGATIONS & LANDSCAPING, INC., a
Florida       corporation;      SUMMERPARK
HOMES,        _INC.,   a Florida corporation;
BROWN + COMPANY ARCHITECTURE,
INC., a Florida corporation,

        Crossclaim Defendants.
                                                      /

DON KING’S CONCRETE, INC., a Florida
corporation,

         Third-Party Plaintiff,

Vv.


E.R.O. CONSTRUCTION, INC., a Florida
corporation; LIOS CONCRETE CORP., a
Florida    corporation; and ATLANTIC


                                                    Page 2 of 4
CASE NO.:      2020-CA-002942


 CONCRETE            SYSTEMS,      INC.,   a Florida
 corporation.

            Third-Party Defendants.



 THIRD-PARTY DEFENDANT, ATLANTIC CONCRETE SYSTEMS, INC’S MOTION
 FOR ENLARGEMENT OF TIME TO DISCLOSE EXPERT(S) AND SERVE EXPERT
                        WITNESS REPORT(S)
       COMES         NOW, Third-Party Defendant, ATLANTIC                 CONCRETE           SYSTEMS,   INC., by
and through its undersigned counsel, and pursuant to Fla. R. Civ. P. 1.090(b), hereby files its
Motion for Extension of Time to Disclose Expert(s) and Serve Expert Witness Report(s), and in
support thereof states as follows:

        1       On   April   9, 2021,   this     Court    entered    its Complex      Case   Management    Order
                (“CCMO”) setting the trial of this matter for November 2022, with a discovery cut-
                off
                 of June 30, 2022.
                Pursuant to the CCMO, the deadline for Third-Party Defendants to file their expert
                witness disclosures, including reports, is November 1, 2021.
                However,     the deposition of Plaintiff's primary liability expert witness was only
                recently concluded (on October 28, 2021).
                Accordingly,    the undersigned          counsel    for Third-Party    Defendant,   ATLANTIC
                CONCRETE        SYSTEMS,         INC., requires a brief extension of time to disclose its
                expert(s) and serve its expert(s) reports, and will do so on or before December                1,
                2021.
                This Motion is made in good faith and not for purposes of delay, and the granting of
                this Motion shall not harm or prejudice any party, especially since discovery cut-off
                is not until June 2022 and trial is approximately one (1) year away.

       WHEREFORE,            Third-Party       Defendant,    ATLANTIC        CONCRETE          SYSTEMS,    INC.,
respectfully requests that this Honorable Court enter an Order granting its Motion for Extension
of Time to Disclose Expert(s) and Serve Expert Witness Report(s), and extending the time for
disclosure of expert(s) and expert reports to December                1, 2021, and providing for such further
relief as the Court deems just and appropriate in the premises.


                                                    Page 3 of 4
CASE NO.:    2020-CA-002942




                                CERTIFICATE OF SERVICE

       Thereby certify that a true and correct copy of the foregoing has been furnished all counsel

of record using the Florida Courts E-Filing Portal, on this 29" day of October 2021.

                                     Attorney for Third-Party Defendant
                                     Atlantic Concrete Systems, Inc.
                                     Law Office of Jennifer L. Shippole
                                      14050 NW 14" Street, Suite 180
                                      Sunrise, Florida 33323
                                      Phone: 954-417-3066 Ext. 4645
                                      E-mail:   jlspleadings@fednat.con
                                                nseropian@fednat.com
                                                jshippole@fednat.com

                                       /s/ Nicole Seropian
                                      NICOLE SEROPIAN, ESQUIRE
                                      FL Bar No.: 797405
                                      JENNIFER SHIPPOLE, ESQUIRE
                                      FL Bar No.: 130760




                                            Page 4 of 4