Plaintiffs’ Motion for Extension of time 

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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF FLORIDA

PENSACOLA DIVISION

MATHEW SELOVER

Plaintiff, 

vs. CASE NUMBER: 3:20-CV-4698-

TKW-HTC

 

ESCAMBIA COUNTY BOARD

OF COUNTY COMMISSIONERS and

RAYME EDLER, 

Defendants.

 /

PLAINTIFF’S UNOPPOSED MOTION 

FOR EXTENTION OF TIME TO RESPOND TO DEFENDANTS’

MOTIONS TO DISMISS THE AMENDED COMPLAINT

COMES NOW, the Plaintiff, MATHEW SELOVER, by and through the 

undersigned counsel hereby moves this Court for an extension of time to file 

Plaintiff’s Response to Defendants’, Escambia County Board of County 

Commissioners and Rayme Edler (in her official capacity) (collectively referred to 

as the Board), and Rayme Edler’s (in her individual capacity)1 respective motions to 

dismiss the Amended Complaint. In support of this motion, the Plaintiff states as 

follows:

1. This case was originally filed in Escambia County Circuit Court on or 

1 All defendants collectively referred to as “Defendants.” 

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Plaintiffs’ Motion for Extension of time 

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about January 17, 2020 raising distinct causes of action against the 

Board, and Defendant Edler in her individual capacity.

2. After Defendants removed the case to this Court, and filed separate 

motions to dismiss, Plaintiff filed an amended complaint on or about 

April 23, 2020 which included additional causes of action based on 

newly discovered evidence.

3. In response to the Amended Complaint, Defendants filed separate 

motions to dismiss on or about May 16, 2020.

4. In their respective motions to dismiss, Defendants raise separate, and 

distinct arguments in support of their requests for dismissal.

5. Plaintiff’s responses to Defendants’ respective motions to dismiss are

due on June 1, 2020. 

6. Because Plaintiff is preparing responses to two separate and distinct 

motions to dismiss, Plaintiff’s counsel needs additional time to confer 

with Plaintiff, and prepare the responses.

7. Thus, Plaintiff respectfully requests this Court grant Plaintiff a seven

(7) day extension to respond to the Board’s Motion to Dismiss, making 

the deadline Monday, June 8, 2020.

8. This motion is made in good faith, and not for the purposes of delay. 

Further, the short time extension requested herein will not prejudice 

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Plaintiffs’ Motion for Extension of time 

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Defendants. 

9. Plaintiff’s counsel has conferred with Defendants’ counsel regarding 

the relief requested herein, and the Defendants’ counsel has confirmed 

in writing that Defendants DO NOT OBJECT to the short time 

extension requested herein. 

WHEREFORE, the Plaintiff, MATHEW SELOVER, respectfully requests

this Court grant the Plaintiff a seven (7) day extension to respond to the Board’s

Motion to Dismiss, making the deadline Monday, June 8, 2020.

Respectfully submitted,

/s/ Travis P. Lampert

JEREMIAH J. TALBOTT, ESQ.

Florida Bar No. 0154794

TRAVIS P. LAMPERT, ESQ. 

Florida Bar No. 0099843

Law Office of Jeremiah J. Talbott, P.A.

900 East Moreno Street

Pensacola, FL 32503

(850) 437-9600 / (850) 437-0906 (facsimile)

Attorneys for Plaintiff

jjtalbott@talbottlawfirm.com

civilfilings@talbottlawfirm.com

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1(B)

I HEREBY CERTIFY that the undersigned has complied with Local Rule 

7.1(B), and the Board’s counsel has advised there is NO OBJECTION to the relief 

requested above. 

/s/ Travis P. Lampert

TRAVIS P. LAMPERT, ESQ.

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Plaintiffs’ Motion for Extension of time 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 27th day of May, 2020 a true and correct 

copy of the foregoing Response was furnished to counsel for the Defendants as listed 

below via CMC/ECF.

/s/ Travis P. Lampert

TRAVIS P. LAMPERT, ESQ.

SERVICE LIST

Stephanie Pidermann, Esquire

Lydecker Diaz

1221 Brickell Avenue, 19th Floor

Miami, FL 33131

sp@lydeckerdiaz.com

kg@lydeckerdiaz.com

ksm@lydeckerdiaz.com

Cecily L. Kaffer, Esq.

The Kullman Firm

P.O. Box 1287

Mobile, AL 36633

clk@kullmanlaw.com

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