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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

BRANDON THOMPSON 

Plaintiff,

v.

FORT LAUDERDALE LAW GROUP 

SOUTH, PLLC,

Defendant.

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Case No. 0:20-cv-60885

JOINT MOTION TO EXTEND VARIOUS DEADLINES AND AMEND CASE 

MANAGEMENT ORDER

Defendant, FORT LAUDERDALE LAW GROUP SOUTH, LLC., (“Defendant”) and 

Plaintiff BRANDON THOMPSON respectfully move pursuant to Federal Rule 6(b) for an

extension of time of deadlines set in the Court’s Order Setting Trial and Pre-Trial Schedule (see

Doc. 24) and the upcoming Status Conference (see Doc. 45) and state the following in support: 

1. On or about July 7, 2020, the Court filed the Order Setting Trial and Pre-Trial Schedule

(Doc. 24).

2. On or about July 14, 2020, the Court filed an Order Scheduling Status Conference (Doc. 

29) to be held on July 21, 2020. The findings of the conference were that counsel continue to 

correspond and cooperate with each other, but settlement has not been reached at that time.

3. On or about July 22, 2020, the Court filed an Order Scheduling Settlement Conference 

(Doc. 34) before Magistrate Judge Patrick Hunt to be held on August 6, 2020. The Settlement 

Conference concluded at an Impasse.

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4. On or about July 24, 2020, in accordance with the Court’s Order (Doc. 24), the Parties 

selected a mediator and scheduled mediation to be held on November 11, 2020. The deadline to 

hold mediation is November 12, 2020.

5. On or about August 7, 2020, a second status conference was scheduled for August 13, 2020 

(see Doc. 39). The findings of the conference were that counsel continue to correspond and 

cooperate with each other, but settlement has still not been reached at that time. A third status 

conference was scheduled to be held on September 24, 2020 (Doc. 41).

6. On or about September 21, 2020, the Court re-scheduled the status conference to 

September 30, 2020. The findings of the conference were that counsel continue to correspond and 

cooperate with each other, but settlement has still not been reached at that time.

7. At that conference, counsel reported to the Court that document discovery had been 

undertaken but the parties remained at odds regarding the amount of time actually worked by Mr. 

Thompson. Counsel for both parties agreed that depositions of Plaintiff, and Defendant’s corporate 

representative are needed. Counsel for both parties are attempting to schedule these depositions on 

the same day and are attempting to limit them to approximately four hours. However scheduling 

coordination on the depositions had been challenging, leading to the current motion for extension 

of deadlines. The earliest time that all deponents and counsel can convene would be late December.

This is due, in part, to challenges with balancing an active litigation with the ongoing Covid 19 

pandemic, and Defendant continuing to operate a law office.

8. A fourth status conference is scheduled to be held on October 30, 2020 (Doc. 45).

9. Per the Order Setting Trial and Pre-Trial Schedule (Doc. 24), the deadline for parties to 

complete all discovery is set for November 3, 2020.

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10. In light of the fact that counsel is coordinating depositions which may impact deadlines 

currently set, the Parties request additional time to comply with the Court’s Case Management 

Order (Doc. 24). Specifically, the parties request:

a. The status conference currently scheduled for October 30, 2020 be moved out to 

January 8, 2020. 

b. The deadline for parties to complete discovery currently set for November 3, 2020 

be moved out to February 3, 2021.

c. The deadline to hold mediation be moved out from November 12, 2020 to February 

19, 2021. The parties will reschedule the mediation to be held sometime after the 

depositions currently being scheduled.

d. The deadline to file all pre-trial motions, including motions for summary judgment, 

and Daubert motions be moved out from December 2, 2020 to June 4, 2021.

e. The deadline to submit a joint pre-trial stipulation, exhibit lists, witness lists, 

depositions, and proposed jury instructions and verdict form and motions in limine

be moved out from February 12, 2021 to June 18, 2021.

f. The calendar call for trial scheduled for February 23, 2021 be moved out to July 

19, 2021.

11. The Parties are working cooperatively to assess the next steps in this case. Furthermore, 

counsel for the parties continue to engage in discussions to determine if amicable resolution is 

possible. Given the Southern District of Florida’s recent administrative order (Administrative 

Order 2020-76) continuing all jury trials until after April 5, 2021, the Parties understand that there 

appears no chance a trial scheduled for February would be able to move forward. Accordingly, the 

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Parties seek to extend these deadlines to coordinate depositions in a manner that is efficient for all 

individuals involved.

12. Additionally, the Parties have continually and steadfastly informed the Court of the state 

of the matter through multiple status conferences.

13. This extension is not being sought for the purposes of delay, nor will this brief extension 

prejudice any party to the litigation.

WHEREFORE, the Parties jointly and respectfully request an extension of time of 

deadlines set in the Court’s Order Setting Trial and Pre-Trial Schedule (Doc. 24) and the next 

scheduled Status Conference (Doc. 45).

DATED this 26th day of October, 2020.

Respectfully submitted,

Spire Law, LLC /s/ Alexander T. Harne

2572 W. State Road 426, Suite 2088 Alexander T. Harne, Esq.

Oviedo, Florida 32765 Florida Bar No. 126932

/s/ Noah E. Storch

By:/s/Jesse I. Unruh Noah E. Storch, Esq,

Jesse I. Unruh, Esq. Florida Bar No. 85476

Florida Bar No. 91121 RICHARD CELLER LEGAL, P.A.

jesse@spirelawfirm.com 10368 W. State Road 84, Suite 103

lauren@spirelawfirm.com Davie, Florida 33324

Telephone: (866) 344-9243

Attorney for Defendant | FORT Facsimile: (954) 337-2771

LAUDERDALE LAW GROUP Email: aharne@floridaovertimelawyer.com

SOUTH, LLC noah@floridaovertimelawyer.com

Counsel for Plaintiff

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CERTIFICATE OF SERVICE

I hereby Certify that on this 26th day of October, 2020., the foregoing was electronically 

filed with the Court by using the Southern District of Florida’s CM/ECF portal, which will send a 

notice of electronic filing to: Noah E. Storch, Esquire and Alexander T. Harne, Esquire at 

noah@floridaovertimelawyer.com and aharne@floridaovertimelawyer.com at 10368 West State 

Road 84, Suite 103, Davie, FL 33324.

/s/ Jesse Unruh

Jesse Unruh

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