UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

Case No. 20-cv-60885-RKA

BRANDON THOMPSON, 

Plaintiff, 

v. 

FORT LAUDERDALE LAW GROUP SOUTH, PLLC, 

A Florida Limited Liability Company, 

Defendant. 

____________________________________/

JOINT MOTION FOR EXTENSION OF TIME 

TO CONDUCT SCHEDULING CONFERENCE

Plaintiff, Brandon Thompson (“Plaintiff”), and Defendant, Fort Lauderdale Law Group 

South, PLLC, (“Defendant”) (collectively, the “Parties”), by and through undersigned counsel, 

hereby file this Joint Motion of Extension of Time to Conduct Scheduling Conference, and, in

support thereof, states as follows:

1. Plaintiff filed his complaint on May 1, 2020. See ECF No. 1.

2. Defendant was served on May 13, 2020, and, therefore, the response is not due until June 

3, 2020. See ECF No. 4.

3. Defendant filed its Motion for Extension of Time to Respond to Plaintiff’s Complaint on 

June 3, 2020. See ECF No. 7.

4. At this time, counsel has not appeared for Defendant. 

5. The Parties are directed to file a Joint Scheduling Report, due by June 15, 2020. See ECF 

No. 8.

6. The Defendant has not secured counsel to date. 

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7. Further, in lieu of this Court’s Order, ECF No. 11, the Parties are directed to either file a 

Notice of Settlement or a Notice of Non-Settlement by June 16, 2020. 

8. Therefore, the Parties request a seven (7) day extension of time, from June 15, 2020 (the 

date on which the Parties’ Joint Scheduling Report is due), to allow further settlement 

discussions and conduct the required scheduling conference within the given timeframe. 

9. This Motion is not made for purposes of delay, nor will there be any prejudice.

MEMORANDUM OF LAW

Rule 16 of the Federal Rules of Civil Procedure provides that once entered, the 

scheduling order “shall control the subsequent course of the action unless modified by a 

subsequent order . . . [and] “shall not be modified except upon a showing of good cause.” 

Fed.R.Civ.P. 16(b)(e). 

The Parties are directed to file a Joint Scheduling Report, due by June 15, 2020. See ECF 

No. 8. Service was delayed due to the service company suspended service as a result of the 

COVID-19 pandemic and the Defendant has yet to secure representative at this time. As such, 

the scheduling conference cannot occur within the time prescribed by this Court. 

Therefore, the Parties requests a seven (7) day extension of time, from June 15, 2020 (the 

date on which the Parties Joint Scheduling Report is due), to conduct the scheduling conference. 

WHEREFORE, for the reasons discussed above, the Parties requests a seven (7) day

extension of time, from June 15, 2020 (the date on which the Parties’ Joint Scheduling Report is 

due), to conduct the scheduling conference. 

Dated this 15th day of June 2020.

Respectfully Submitted, 

/s/ Noah E. Storch_____

Noah E. Storch, Esquire

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Florida Bar No. 0085476

RICHARD CELLER LEGAL, P.A.

10368 West State Road 84, Suite 103 

Davie, Florida 33324 

Telephone: (866) 344-9243

Facsimile: (954) 337-2771

Email: noah@floridaovertimelawyer.com

Attorneys for Plaintiff

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been filed with 

the Court’s CM/ECF electronic filing system which will send a copy to all counsel of record 

on this 15th day of June 2020. 

s/Noah E. Storch

Noah E. Storch, Esq.

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